Anti-Money Laundering and Countering the Financing of Terrorism Programs

The Financial Technology Association (FTA) supports the proposed rule to reform AML/CFT program requirements, praising its shift toward a risk-based approach and the use of innovative technologies. However, they request specific regulatory language to protect institutions from penalties for good-faith resource redeployment, a longer 24-month implementation timeline, and the extension of "significant or systemic" enforcement thresholds to non-bank financial institutions.

The National Association of State Credit Union Supervisors (NASCUS) supports the proposed rule because it modernizes AML/CFT requirements by emphasizing a risk-based approach and program effectiveness. They argue that the proposal allows institutions to tailor resources to their specific risk profiles while maintaining continuity with existing frameworks.

GECU Federal Credit Union supports the NCUA's proposed rule to modernize AML/CFT programs by adopting a risk-based framework that focuses on program effectiveness rather than just procedural compliance. The commenter requests additional guidance and clarity on specific definitions of "significant" failures, the consultation process with FinCEN, and the notification procedures for supervisory actions.

The Defense Credit Union Council (DCUC) supports the proposed transition toward a risk-based AML/CFT framework, noting that it allows credit unions to allocate resources more effectively based on their specific risk profiles. They urge the NCUA to ensure the final rule preserves flexibility for smaller institutions, provides consistent examiner training, and allows for a meaningful implementation period of 18-24 months.

TIAA, a retirement solutions and wealth management provider, expresses strong support for the proposed risk-based AML/CFT framework while requesting specific refinements. The organization argues for clearer language that allows institutions to exclude low-risk transactions from monitoring, implement role-appropriate training, and use innovative technologies like AI to improve compliance efficiency.

The Wisconsin Credit Union League supports the proposed AML/CFT rules, praising the shift toward a risk-based, outcomes-oriented regulatory framework that reduces prescriptive burdens. However, the organization requests specific clarifications on "material" failures, the definition of "significant" enforcement actions, and the documentation of national AML/CFT priorities. They also urge the NCUA to address a specific issue regarding duplicative Currency Transaction Report (CTR) filings for armored car cash deliveries in Wisconsin.

America’s Credit Unions supports the proposed AML/CFT program modernization but urges the NCUA to ensure consistent supervision with FinCEN and to focus on significant, systemic failures rather than minor technical issues. They advocate for practical implementation requirements, clear definitions of supervisory actions, and robust protections for confidential and privileged information.

The Institute of International Bankers (IIB) supports the proposed AML/CFT program rules, particularly the shift toward a risk-based approach and the reduction of "check-the-box" compliance burdens. They request specific clarifications regarding the distinction between "establishing" and "maintaining" programs, definitions for "significant or systemic" failures, and more flexibility for banks to update risk assessments and allocate resources based on their unique risk profiles.

The Michigan Credit Union League is commenting on behalf of its members, expressing general support for the proposed AML/CFT program framework while advocating for specific clarifications. They request clearer distinctions between mandatory requirements and supervisory guidance, more precise definitions for "significant failures," and a risk-based approach that avoids overly prescriptive "one-size-fits-all" requirements for smaller institutions.

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 model validation, list-based screening, and rigid risk assessments in favor of using open-source intelligence and transaction monitoring to address national security threats.