Kharon
KharonSupportAdvocacy
Summary: Kharon, a risk intelligence company, supports the proposed rule's shift toward outcome-driven, risk-based AML/CFT practices that prioritize national security. They argue for reducing "low-value" legacy requirements—such as excessive model validation for fuzzy logic and rigid employee screening—in favor of using open-source intelligence and transaction data to detect sophisticated sanctions evasion and export control risks.
Please see comment attached.