The Wolfsberg Group
The Wolfsberg GroupSupportAdvocacy
Summary: The Wolfsberg Group supports the proposed rule as a significant step toward modernizing the U.S. AML/CFT regime and moving toward a risk-based approach. They recommend specific technical edits to codify clarity on "effective" program definitions, resource allocation flexibility, and the use of innovative technologies, while also requesting an extension of the effective date to allow for necessary coordination with the FFIEC Manual.
The Wolfsberg Group appreciates the opportunity to comment on the Federal Banking Agencies’ Notice of Proposed Rulemaking (NPRM) for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Programs, and related proposed revisions to AML/CFT programs from FinCEN. We value the U.S. Government’s ongoing, meaningful engagement on AML/CFT reform. Please find attached our comment letter with accompanying appendices.