Summary -

Press reporting on thousands of leaked Suspicious Activity Reports (SARs) filed by financial institutions with the U.S. Financial Crimes Enforcement Network (FinCEN) has highlighted longstanding challenges to current anti-money laundering and countering the financing of terrorism (AML/CFT) efforts. Against this backdrop, the announcement that FinCEN is seeking public comment on important reforms to its regulations provides a critical opportunity for financial institutions and other stakeholders to begin shaping the future of the AML/CFT regime. FinCEN’s Advanced Notice of Prospective Rulemaking (ANPRM), which requests input by November 16, 2020, validates longstanding private sector sentiment about the need to improve the effectiveness and efficiency of the AML/CFT regime.