Comment from Institute of International Bankers

Summary: The Institute of International Bankers (IIB) supports the proposed AML/CFT program rules, particularly the shift toward a risk-based approach and the reduction of "check-the-box" compliance burdens. They request specific clarifications regarding the distinction between "establishing" and "maintaining" programs, definitions for "significant or systemic" failures, and more flexibility for banks to update risk assessments and allocate resources based on their unique risk profiles.