Comment from The Wolfsberg Group
The Wolfsberg GroupSupportAdvocacy
Summary: The Wolfsberg Group supports the proposed rule as a critical step toward modernizing the U.S. AML/CFT regime and moving toward a risk-based approach. They recommend specific refinements to codify clarity on program effectiveness, resource allocation, and the use of innovative technologies, while also requesting an extension of the effective date to allow for coordination with other regulatory manuals.
The Wolfsberg Group appreciates the opportunity to comment on FinCEN’s Notice of Proposed Rulemaking (NPRM) for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Programs, and related proposed revisions to AML/CFT programs from the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration. We value the U.S. Government’s ongoing, meaningful engagement on AML/CFT reform. Please find attached our comment letter with accompanying appendices.