Comment from Conference of State Bank Supervisors (CSBS)
Conference of State Bank Supervisors (CSBS)SupportTrade association
Summary: The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators, supports the proposed modernization of AML/CFT program requirements to create a risk-based regime. They specifically advocate for distinguishing between program design and implementation, prioritizing high-risk activities, and adopting an optional rather than mandatory FinCEN consultation process for enforcement actions to maintain supervisory efficiency.
See attached comments from the Conference of State Bank Supervisors (CSBS).