On 6/30/2021, the Financial Crimes Enforcement Network (FinCEN) issued a set of government-wide priorities for anti-money laundering and countering the financing of terrorism policy. The Priorities identify and describe the most significant AML/CFT threats currently facing the United States and include: corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and human smuggling, and proliferation financing. FinCEN also issued two statements to provide guidance to covered institutions on how to approach the Priorities.
In their release, FinCEN explains that it will update these Priorities to highlight new or evolving AML/CFT threats at least once every four years, as required by the AML Act. In addition, FinCEN explains that covered institutions are not required to make any immediate changes to their risk-based AML programs in response to these Priorities as FinCEN will propose implementing regulations in the coming months. Furthermore, FinCEN explained that they, the Federal functional regulators, and State regulators will not examine any covered institution for the incorporation of the Priorities into their risk-based AML programs until implementing regulations have been promulgated. Nevertheless, in preparation for any new requirements when those final rules are published, covered institutions may wish to start considering how they will incorporate the AML/CFT Priorities into their risk-based AML programs.
FinCEN’s press release can be found here.
FinCEN’s AML/CFT priorities can be found here.
The interagency statement can be found here.
The FinCEN statement can be found here.