HSBC North America Holdings, Inc.
HSBCSupportBusiness
Summary: HSBC supports the proposed rule but recommends adding specific language to explicitly encourage and protect the use of innovative technologies, such as AI and machine learning, in AML/CFT programs. They argue that the final rule should clarify that financial institutions will not be penalized for prioritizing high-risk activities over low-risk ones or for choosing not to participate in certain public-private information-sharing initiatives.
To Whom It May Concern:
Attached please find HSBC’s comments on the Notice of Proposed Rulemaking on AML/CFT Programs (Docket ID: OCC-2024-0005, RIN 1557-AF14).
Thank you very much for the opportunity to comment.
Kind regards,
Andrea Aronoff (she/hers)
Director, US Head of AML, AB&C and Tax Transparency
HSBC North America Holdings, Inc.
66 Hudson Blvd, New York, NY 10001