Comment from FGA Action
FGA ActionSupportAdvocacy
Summary: FGA Action supports the proposed rule's shift toward a risk-based AML/CFT framework but argues that the final rule must explicitly prioritize fraud against taxpayer-funded programs. They also advocate for making anti-debanking protections into binding regulatory text to ensure that financial institutions perform individualized risk assessments rather than engaging in broad category-wide account closures.
See attached file(s)