Comment from Kharon
KharonSupportBusiness
Summary: Kharon, a risk intelligence company, supports the proposed AML/CFT rule because it allows financial institutions to shift resources from low-value legacy requirements to high-risk, outcome-driven practices. They argue for reducing burdens related to model validation, list-based screening, and rigid risk assessments in favor of using open-source intelligence and transaction monitoring to address national security threats.
Please see comment attached.