Comment from Financial & International Business Association, Inc. (FIBA)
Financial & International Business Association, Inc.SupportTrade association
Summary: The Financial & International Business Association, Inc. (FIBA) supports the proposed rule to modernize AML/CFT program requirements but urges FinCEN to ensure the final rule prioritizes a risk-based approach over "check-the-box" compliance. They specifically advocate for transparent examination standards, clearer definitions of "effective" programs, and protections for institutions that de-prioritize lower-risk activities.
The Financial & International Business Association, Inc. appreciates the opportunity to provide the attached comments to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network regarding FinCEN’s proposed rule to modernize and reform anti-money laundering and countering the financing of terrorism program requirements for financial institutions pursuant to the Anti-Money Laundering Act of 2020.