FinCEN Issuing Proposed Rule Impacting BSA/AML Risk Assessments

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On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it is issuing a proposed rule impacting Bank Secrecy Act (BSA)/Anti Money Laundering (AML) risk assessments, among other things. The proposed rule would amend existing regulations in three ways:

  1. Explicitly require financial institutions to establish, implement and maintain effective, risk-based, and reasonably designed AML/Countering the Financing of Terrorism (CFT) programs with certain minimum components, including a mandatory risk assessment process.
  2. Require financial institutions to review government-wide AML/CFT priorities and incorporate them, as appropriate, into risk-based programs, as well as provide for certain technical changes to program requirements.
  3. Promote clarity and consistency across FinCEN’s program rules for different types of financial institutions.

Most financial institutions have an established BSA/AML risk assessment, so these changes should not significantly impact them. However, placing a requirement to review government-wide AML/CFT priorities and incorporate them into compliance programs will likely impact most financial institutions as their BSA/AML risk assessments do not currently address all the AML/CFT priorities.

If your financial institutions needs assistance ensuring compliance with BSA/AML regulations, our regulatory compliance specialists are here to help. 

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John Zasada
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John Zasada is a Principal in Doeren Mayhew's Financial Institutions Group, where he assists financial institutions in navigating regulatory compliance.

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