The Financial Crimes Enforcement Network (FinCEN) issued the first government-wide priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) policy following consultation with other relevant Department of the Treasury offices, as well as Federal and State regulators, law enforcement, and national security agencies.
These priorities identify and describe the most significant AML/CFT threats currently facing the United States. In no particular order, these include: corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and human smuggling, and proliferation financing.
FinCEN’s acting director Michael Mosier, said in a statement that the move is a significant milestone for efforts to improve the efficiency and effectiveness of the nation’s AML/CFT regime and to foster greater public-private partnerships: “The priorities reflect the US Government’s view of the threat landscape — highlighting longstanding threats like corruption, fraud, and international terrorism, as well as rapidly evolving and acute threats, such as domestic terrorism, and ransomware and other cybercrime.”
The aim is to assist covered institutions in their AML/CFT efforts and enable those institutions to prioritize the use of their compliance resources. In particular, the priorities highlight key threat trends as well as informational resources that can assist covered institutions in managing their risks. Coupled with the Department of the Treasury’s 2020 Illicit Finance Strategy and 2018 National Risk Assessment, the priorities aim to help covered institutions assess their risks, tailor their AML programs, and prioritize their resources.
This publication of the AML/CFT Priorities does not create an immediate change to Bank Secrecy Act (BSA) requirements or supervisory expectations for banks. The AML Act requires that, within 180 days of the establishment of the AML/CFT priorities, FinCEN (in consultation with Federal functional regulators and relevant State financial regulators) shall, as appropriate, promulgate regulations regarding the AML/CFT Priorities. Although not required by the AML Act, the FBAs plan to revise their BSA regulations, as necessary, to address how the AML/CFT Priorities will be incorporated into banks’ BSA requirements.
FinCEN will update these priorities to highlight new or evolving AML/CFT threats at least once every four years, as required by the AML Act. As further described in today’s AML/CFT Priorities statements, covered institutions are not required to make any immediate changes to their risk-based AML programs in response to these priorities. FinCEN will propose implementing regulations in the coming months.