Comment from Moody's
Moody'sSupportBusiness
Summary: Moody’s Corporation, a provider of data and analytical tools for financial institutions, supports FinCEN’s proposal to modernize AML/CFT program requirements by focusing on effectiveness and risk-based decision-making rather than prescriptive compliance. The company advocates for clearer supervisory expectations regarding the distinction between program establishment and maintenance, proportionality for different institution sizes, and the dynamic integration of national illicit finance priorities.
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