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The heart of FinCEN’s recent ANPRM

ANPRM = Advance Notice of Proposed Rulemaking

From the ANPRM, until it gets into the nitty-gritty…

Specifically, FinCEN is considering regulatory amendments that would explicitly define an “effective and reasonably designed” AML program as one that:
 Identifies, assesses, and reasonably mitigates the risks resulting from illicit financial activity — including terrorist financing, money laundering, and other related financial crimes — consistent with both the institution’s risk profile and the risks communicated by relevant government authorities as national AML priorities;
 Assures and monitors compliance with the recordkeeping and reporting requirements of the BSA; and
 Provides information with a high degree of usefulness to government authorities consistent with both the institution’s risk assessment and the risks communicated by relevant government authorities as national AML priorities.
As explained in more detail in the sections that follow, this ANPRM also seeks comment
on whether the AML program regulations21 should be amended to establish an explicit requirement for a risk-assessment process, as well as whether the Director of FinCEN should issue every two years a list of national AML priorities, to be called FinCEN’s “Strategic Anti- Money Laundering Priorities.”

Oh, I think I like that… I find when I cut and paste, I sometimes get this tiny type size. Avoiding eye strain is always a good idea…

Categories: Advance Notice of Proposed Rulemaking (ANPRM) Anti-Money Laundering Consultations FinCEN Updates Public Consultations Risk-Based Approach

eric9to5

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