Key recommendations to FinCEN include:
- Provide Maximum Flexibility for Risk Assessment Processes;
- Revise Requirements for Risk Assessment Processes;
- Clarify Requirements for U.S.-Based AML/CFT Management;
- Define Expectations for AML Program Effectiveness; and
- Significantly Extend the Implementation Time for firms.
Firms can view the Group’s response to the now-closed consultation in advance of potential forthcoming changes to FinCEN rules and requirements