Steps For Complying With FinCEN's New AML Priorities

By Satish Kini, Zila Acosta-Grimes and Jonathan Wong (August 25, 2021, 6:38 PM EDT) -- On June 30, the Financial Crimes Enforcement Network issued governmentwide priorities for anti-money laundering and countering the financing of terrorism[1] — or AML and CFT, respectively — as required by the Anti-Money Laundering Act.[2]

The priorities were issued with additional statements to banks[3] and nonbank financial institutions[4] on their expected use and applicability.

FinCEN's issuance of the priorities does not, in itself, change compliance obligations for financial institutions.

But, as also required by the AMLA, FinCEN will issue further regulations addressing how the priorities should inform AML and CFT compliance efforts.

To that end, in its statements accompanying the priorities, FinCEN noted that...

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