Comment from TIAA
TIAASupportBusiness
Summary: TIAA, a retirement solutions and wealth management provider, expresses strong support for the proposed risk-based AML/CFT framework. The organization argues for greater clarity on "risk-based" definitions, the ability to exclude low-risk transactions from monitoring, and the use of AI and innovative technologies to improve compliance efficiency.
TIAA hereby submits the attached comment letter in response to FinCEN's "Anti-Money Laundering and Countering the Financing of Terrorism Programs" proposal, Docket No. FINCEN–2026–0034; RIN 1506–AB72.