Snapshot:
On July 7, the Federal Reserve requested comment on proposed amendments to its anti-money laundering program requirements, which would require supervised banks to maintain AML/CFT programs reasonably designed to identify, assess, and mitigate illicit finance risks. The proposal would further align AML program expectations with FinCEN priorities and reinforce a risk-based approach to compliance.
- The proposal would require AML/CFT programs that are reasonably designed to identify, assess, and mitigate illicit finance risks.
- Banks would be expected to focus AML resources on higher-risk customers and activities.
- Institutions would be required to incorporate FinCEN’s AML/CFT Priorities into their risk assessment processes.
- The proposal is intended to align Federal Reserve requirements with broader AML/CFT modernization efforts underway across the regulatory landscape.
Why it Matters:
The proposal continues the regulatory shift toward effectiveness-based AML compliance. Rather than focusing solely on processes and documentation, regulators are increasingly emphasizing whether programs appropriately identify and mitigate risk. For BSA and compliance leaders, the proposal reinforces the need for strong risk assessments, effective allocation of compliance resources, and demonstrable alignment with FinCEN’s national AML priorities.
Official Sources:
Federal Reserve Board Requests Comment on a Proposal to Amend Its Requirements for Banks to Maintain Anti-Money Laundering Programs
Federal Register Notice: Anti-Money Laundering and Countering the Financing of Terrorism Programs