Financial Crime World

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AML/CFT Best Practices for Banks in Saint Pierre and Miquelon

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule aimed at strengthening and modernizing anti-money laundering (AML) and countering the financing of terrorism (CFT) programs. The new regulations would require financial institutions, including banks in Saint Pierre and Miquelon, to establish and maintain effective, risk-based AML/CFT programs.

Promoting Clarity and Consistency

The proposed rule seeks to promote clarity and consistency across different types of financial institutions, including those in Saint Pierre and Miquelon. The regulation would apply to a wide range of financial institutions, including:

  • Banks
  • Casinos
  • Money services businesses
  • Broker-dealers
  • Insurance companies

Key Components of the AML/CFT Program

The key components of an effective AML/CFT program include:

  • Mandatory Risk Assessment Process: Incorporates FinCEN’s AML/CFT priorities
  • Internal Policies and Procedures: Manage and mitigate identified risks
  • Designated AML/CFT Officer: Coordinates and monitors compliance
  • Ongoing Employee Training Programs: Focuses on risk areas identified in the risk assessment process
  • Independent Testing: By qualified personnel or outside parties

Additional Requirements

The regulation also emphasizes the importance of:

  • Board Oversight and Approval: For AML/CFT programs
  • Customer Due Diligence: To ensure compliance with regulatory requirements
  • Maintaining Records: Accurate and complete records are essential for compliance and monitoring

Supervisory Intensity and Enforcement Activity

Financial institutions in Saint Pierre and Miquelon are advised to expect continued supervisory intensity and enforcement activity on AML/CFT/BSA compliance. To stay ahead of regulatory requirements, financial institutions should:

  • Continuously assess risk
  • Implement risk-based compliance programs
  • Maintain needed talent/skillsets
  • Tooling/automation
  • Investments

Public Comment Period

The public is invited to comment on the proposed rule until September 3, 2024. The final rule is expected to be effective six months after its issuance date.