Comment from Illinois Credit Union League
Illinois Credit Union LeagueSupportTrade association
Summary: The Illinois Credit Union League (ICUL) supports the proposed rule to align with the Anti-Money Laundering Act of 2020, specifically praising the shift toward a risk-based framework rather than a strict compliance regime. They request additional clarity on distinguishing between "establishing" and "maintaining" programs, as well as guidance on incorporating AML/CFT Priorities into risk assessments.
See attached file(s)