Comment from HSBC
HSBCSupportBusiness
Summary: HSBC, a global financial institution, supports the proposed AML/CFT program rules and applauds the efforts to align them with the AML Act. The bank argues for specific modifications to the final rule that would explicitly encourage the use of innovative technologies, recognize participation in public-private information-sharing partnerships, and allow firms to prioritize resources toward higher-risk activities without fear of regulatory reprisal for not detecting lower-risk activity.
To Whom It May Concern:
Attached please find HSBC’s comments on the Notice of Proposed Rulemaking on AML/CFT Programs (Docket ID: FINCEN–2026–0034, RIN 1506–AB72).
Thank you very much for the opportunity to comment.
Kind regards,
Andrea Aronoff (she/hers)
Director, US Head of AML, AB&C and Tax Transparency
HSBC North America Holdings, Inc.
66 Hudson Blvd, New York, NY 10001