FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report detailing progress in the first 180 days since Congress’ passage of the Anti-Money Laundering Act of 2020 (the “AML Act”). Of note, in late June 2021, FinCEN announced the completion of two key deliverables required by the AML Act:

..First, FinCEN’s report determining it may undertake rulemaking to create a no-action letter issuance process in at least some form, despite practical challenges involved in the endeavor.

..Second, FinCEN’s establishment of national policy priorities within anti-money laundering (“AML”) and counter-financing of terrorism (“CFT”).

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