Comment from Institute of International Bankers (IIB)

Summary: The Institute of International Bankers (IIB) supports the proposed rule to modernize the Bank Secrecy Act framework, praising its focus on high-risk areas and reduction of compliance burdens. The organization requests specific regulatory clarifications regarding the distinction between "establishing" and "maintaining" programs, the definition of "significant or systemic" failures, and the flexibility of risk assessment processes.