Conference of State Bank Supervisors
Conference of State Bank Supervisors (CSBS)SupportAdvocacy
Summary: The Conference of State Bank Supervisors (CSBS) supports the proposed modernization of AML/CFT program requirements to create a risk-based regime that distinguishes between program design and implementation. However, they specifically recommend adopting the optional rather than the mandatory FinCEN consultation process for enforcement actions to maintain supervisory efficiency and avoid regulatory divergence.
See attached comments from the Conference of State Bank Supervisors (CSBS).