Comment from Independent Community Bankers of America (ICBA )

Summary: The Independent Community Bankers of America (ICBA) supports the proposed modernization of AML/CFT programs, particularly the shift toward a risk-based approach that allows community banks to focus resources on higher-risk activities. However, they urge FinCEN to provide clearer implementation guidance, ensure the rule is scalable for smaller institutions with limited staff, and extend the implementation timeline from 12 to 24 months.