Institute of International Bankers
Institute of International BankersSupportAdvocacy
Summary: The Institute of International Bankers (IIB) supports the proposed rule's goals of modernizing AML/CFT programs and reducing unnecessary compliance burdens. They request specific clarifications regarding the distinction between "establishing" and "maintaining" programs, the definition of "significant or systemic" failures, and the inclusion of a "reasonableness" standard for risk-based resource allocations.
Please find the IIB's comment letter in response to the joint agency NPR on AML CFT proposed program rule.