Comment from Forbright Bank
Jessica NicheleSupportBusiness
Summary: Forbright Bank supports FinCEN's AML/CFT modernization efforts but requests additional clarity on how effectiveness is measured and how risk assessments should be updated. The bank argues for a proportionate approach to incorporating National Priorities and risk-based resource allocation to reduce unnecessary operational burdens on financial institutions.
Overall, we support FinCEN’s AML/CFT modernization objective and encourage additional clarity regarding effectiveness, risk assessment expectations, proportionate incorporation of the National Priorities, independent testing, and risk-based resource allocation. We also encourage close interagency coordination and a reasonable implementation period so institutions can adapt their governance, policies, training, and systems in an orderly manner. We appreciate FinCEN’s consideration of these comments.
Please see our attached letter, which contains the full detail of our public comment, including concerns we have about specific provisions.