Comment from Illinois Credit Union League (ICUL)
Illinois Credit Union LeagueSupportTrade association
Summary: The Illinois Credit Union League (ICUL), a trade association representing Illinois credit unions, supports the proposed shift from technical compliance to program effectiveness in AML/CFT requirements. They advocate for clearer definitions regarding "significant or systemic failures" and request additional guidance on incorporating AML/CFT Priorities into risk assessments while emphasizing the need to minimize compliance burdens on smaller institutions.
See attached file(s)