Comment from America's Credit Unions (ACU)

Summary: America’s Credit Unions supports FinCEN’s proposed modernization of AML/CFT programs, specifically praising the shift toward a risk-based approach and the distinction between program establishment and maintenance. They argue that the final rule should preserve flexibility for credit unions of all sizes, avoid imposing unnecessary documentation or technology requirements, and ensure that examiners focus on systemic failures rather than minor, technical issues.