Comment from Settlement Integrity Institute
Settlement Integrity InstituteSupportAdvocacy
Summary: The Settlement Integrity Institute, a standards development organization, supports the joint rulemaking by providing a methodology for evaluating the effectiveness of AML/CFT and sanctions compliance programs. They argue that the agencies should recognize independent methodology layers to provide clear, recertifiable standards for assessing program effectiveness and best practices without foreclosing regulatory authority.
The Settlement Integrity Institute respectfully submits the attached comment letter in response to the FinCEN/OFAC joint Notice of Proposed Rulemaking, Docket No. FINCEN-2026-0100, RIN 1506-AB73. Sincerely, Settlement Integrity Institute.