Comment from Electronic Transactions Association (ETA)

Summary: The Electronic Transactions Association (ETA), a trade association for the payments industry, supports FinCEN's proposed modernization of AML/CFT programs, particularly its focus on risk-based compliance and technological innovation. The organization argues for clearer definitions regarding "material" implementation failures and "establishment" versus "maintenance" obligations to ensure that institutions are not penalized for isolated errors or hindsight-based judgments.