Comment from Foundation for Defense of Democracies

Summary: The Foundation for Defense of Democracies (FDD) supports the proposed rule's shift toward an effectiveness-based AML/CFT framework and the centralization of supervisory authority in FinCEN. However, they argue the rule must be strengthened with specific clarifications to ensure it doesn't create enforcement gaps for national security threats, such as those from Russia, China, and drug cartels, by requiring more robust examiner judgment and full enforcement of the Corporate Transparency Act.