Anti-Money Laundering and Countering the Financing of Terrorism Programs

Section 2 Inc., a financial crime intelligence firm, supports the proposed transition to an "outcome-driven standard of effectiveness" for AML/CFT programs. They argue for specific refinements, including allowing automated configuration updates for national priorities, clarifying that network-based behavioral analytics qualify as "reasonably designed," and ensuring that the "establishment" prong of the rule evaluates structural adequacy against criminal network typologies.

The Crypto Council for Innovation (CCI), a global alliance of digital asset companies, supports the proposed rule to modernize the Bank Secrecy Act with a risk-based AML/CFT framework. They advocate for extending this framework to include non-bank financial institutions, codifying financial institution discretion in the rule text, and providing clearer guidance on the use of innovative technologies like AI.

America’s Credit Unions supports FinCEN’s proposed modernization of AML/CFT programs, specifically praising the shift toward a risk-based approach and the distinction between program establishment and maintenance. They argue that the final rule should preserve flexibility for credit unions of all sizes, avoid imposing unnecessary documentation or technology requirements, and ensure that examiners focus on systemic failures rather than minor, technical issues.

The Institute of International Bankers (IIB) supports the proposed rule to modernize the Bank Secrecy Act framework, praising its focus on high-risk areas and reduction of compliance burdens. The organization requests specific regulatory clarifications regarding the distinction between "establishing" and "maintaining" programs, the definition of "significant or systemic" failures, and the flexibility of risk assessment processes.

Kharon, a risk intelligence company, supports the proposed AML/CFT rule because it allows financial institutions to shift resources from low-value legacy requirements to high-risk, outcome-driven practices. They argue for reducing burdens related to list-based screening and model validation while advocating for a greater focus on open-source intelligence and transaction monitoring to detect national security threats.

Stripe, a money service business and licensed money transmitter, strongly supports the proposed rule's shift toward an outcomes-focused, risk-based AML/CFT compliance framework. They argue that the new approach better aligns with technological innovation and request that FinCEN extend specific enforcement protections and clear definitions of "significant or systemic failure" to non-bank financial institutions like MSBs.

The Illinois Credit Union League (ICUL), a trade association representing Illinois credit unions, supports the proposed shift from technical compliance to program effectiveness in AML/CFT requirements. They advocate for clearer definitions regarding "significant or systemic failures" and request additional guidance on incorporating AML/CFT Priorities into risk assessments while emphasizing the need to minimize compliance burdens on smaller institutions.

Nasdaq Verafin, a global technology company providing financial crime management solutions, supports the proposed rule's shift toward an outcomes-based AML/CFT framework. They argue for greater clarity on what constitutes "effectiveness," advocating for a risk-based approach that prioritizes actionable intelligence for law enforcement and encourages the use of advanced technologies like AI.

The Defense Credit Union Council (DCUC) supports the proposed rule's emphasis on risk-based supervision, program effectiveness, and interagency coordination. They advocate for maintaining flexibility for credit unions, ensuring compliance obligations are proportionate to institutional size and risk, and requesting a meaningful implementation period of at least 18-24 months.

The Global Federation of Insurance Associations (GFIA) supports the proposed reforms to the Bank Secrecy Act, specifically praising the shift toward a risk-based, outcome-focused AML/CFT framework. They advocate for ensuring that the rules reflect the lower risk profile of many insurance products while requesting further clarification on the roles of offshore AML/CFT support functions.