FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)...

First, pursuant to the AML Act, FinCEN published the first government-wide list of anti-money laundering (AML) and countering the finance of terrorism (“AML/CFT”) priorities (the “Priorities”). The Priorities identify and describe the most significant AML/CFT threats facing the United States that financial institutions should be focused on to effectively prioritize their compliance resources and manage their risks. “In no particular order,” FinCEN identified the following eight priorities...

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