Financial institutions should begin preparing for changes to the Bank Secrecy Act (BSA) that respond to new US priorities in anti-money laundering and counter financing of terrorism (AML/CFT) compliance that are expected to be announced by the end of this year according to the US treasury department’s Financial Crimes Enforcement Network (FinCEN).
After FinCEN consulted with other treasury department offices as well as regulators, law enforcement, and national security agencies, the priorities identify and describe the most significant AML/CFT threats currently facing the US.
FinCEN says that, in no particular order, the priorities include corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organisations, drug trafficking organisations, human trafficking and human smuggling, and proliferation financing.
What banks should do
The publication of the AML/CFT Priorities does not create an immediate change to BSA requirements or supervisory expectations for banks according to FinCEN.
It says the AML Act requires that, within 180 days of the establishment of the AML/CFT Priorities, FinCEN, in consultation with regulators “shall, as appropriate, promulgate regulations regarding the AML/CFT Priorities”.
Prepare for new requirements
Banks are not required to incorporate the AML/CFT Priorities into their risk-based BSA compliance programs until the effective date of the final revised regulations.
But FinCEN does suggest that in preparation for any new requirements when those final rules are published, banks may wish to start considering how they will incorporate the AML/CFT Priorities into their risk-based BSA compliance programmes, such as by assessing the potential related risks associated with the products and services they offer, the customers they serve, and the geographic areas in which they operate.
FinCEN says it will update the AML Priorities at least once every four years, as required by law to account for new and emerging threats to the US financial system and national security.
FinCEN’s AML/CFT Priorities Statements, along with an accompanying Interagency Statement and FinCEN Statement can be downloaded from here.
Categories: Trade Based Financial crimes News