Comment from Investment Company Institute (ICI)
Investment Company InstituteSupportTrade association
Summary: The Investment Company Institute (ICI), an association representing the asset management industry, supports FinCEN's efforts to modernize AML/CFT programs and move toward a risk-based approach. However, they request specific clarifications and guidance to ensure that the new requirements do not create redundant burdens or ambiguity for mutual funds, particularly regarding intermediated accounts and the timing of updates.
Good afternoon. The Investment Company Institute appreciates the opportunity to submit comments on FinCEN's proposal related to fundamental reforms of Anti-Money Laundering and Countering the Financing of Terrorism Programs, Docket Number FINCEN-2026-0034; RIN 1506-AB72.