The Financial Crimes Enforcement Network (FinCEN) today issued the first government-wide priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) policy (the “Priorities”), following consultation with other relevant Department of the Treasury offices, as well as Federal and State regulators, law enforcement, and national security agencies. The 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 today also issued two statements (the “AML/CFT Priorities Statements”) to provide guidance to covered institutions on how to approach the Priorities.
“Today’s publication of government-wide AML/CFT Priorities is a significant milestone in FinCEN’s efforts to improve the efficiency and effectiveness of the nation’s AML/CFT regime and to foster greater public-private partnerships,” said Acting Director Michael Mosier. “The Priorities reflect the U.S. 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.”
Today’s publication of the Priorities, issued pursuant to the Anti-Money Laundering Act of 2020 (the “AML Act”), and accompanying AML/CFT Priorities Statements are intended 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.
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. FinCEN, the Federal functional regulators, and State regulators will not examine any covered institution for the incorporation of the Priorities into their risk-based AML programs until implementing regulations have been promulgated. Nevertheless, in preparation for any new requirements when those final rules are published, covered institutions may wish to start considering how they will incorporate the AML/CFT Priorities into their risk-based AML programs.
