Comment from Section 2, Inc.

Summary: Section 2 Inc., a financial crime intelligence firm, supports the proposed transition to an "outcome-driven standard of effectiveness" for AML/CFT programs. They argue for specific refinements, including allowing automated configuration updates for national priorities, clarifying that network-based behavioral analytics qualify as "reasonably designed," and ensuring that the "establishment" prong of the rule evaluates structural adequacy against criminal network typologies.