FinCEN National AML/CFT Priorities - WST

On June 30, 2021, FinCEN, in consultation with other US Dept of the Treasury offices, relevant regulators, law enforcement, and national security agencies, released the first government-wide priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) policy (the “Priorities”). These Priorities were issued pursuant to the Anti-Money Laundering Act of 2020 and are intended, along with interagency statements, to assist financial institutions in their AML/CFT efforts. The Priorities provide a framework to aid financial institutions in organizing their compliance resources so that they can best manage the threats and risks identified.

These first Priorities identify the most significant AML/CFT threats to the United States at this time. In no particular order those threats are:

• Corruption
• Cybercrime
• Domestic and International Terrorist Financing
• Fraud
• Transnational Criminal Organizations
• Drug Trafficking Organizations
• Human Trafficking and Human Smuggling
• Proliferation Financing

Pursuant to the AML Act, these Priorities will be updated a minimum every four (4) years.

So, what does all this mean for you as compliance and IT personnel? First, the publication of the Priorities does not create an immediate change to BSA requirements or expectations for compliance. However, the AML Act of 2020 does require that within 180 days of the publication of the Priorities, appropriate regulations will be promulgated, and the federal banking agencies plan to revise their BSA regulations as necessary to address the Priorities. Even though financial institutions are not required to incorporate the Priorities into their risk-based BSA compliance programs until final regulations are published, you’ll want to take a look at the Priorities now and consider how you plan to incorporate such. Lastly, be aware that once revised regulations are finalized examiners will assess each institution on how well it incorporates these Priorities into their BSA programs.

You can read more about the national Priorities and the interagency statements at the following link: https://www.fincen.gov/sites/default/files/shared/AML_CFT%20Priorities%20(June%2030%2C%202021).pdf

Authored by: Joann Lang, CAMS, CIA, CCBP - September 16th, 2021