Financial Crime World

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Combating Illicit Finance: The United States’ National Approach

The United States has a robust legal and regulatory framework that enables effective domestic cooperation and coordination among law enforcement, regulators, and supervisors. This strong national approach to combating illicit finance is supported by dynamic international cooperation and communication mechanisms.

Detecting and Preventing Suspicious Activity

Financial institutions and other regulated entities play a crucial role in detecting, reporting, and preventing suspicious activity. Supervisors identify and remediate deficiencies at individual institutions to ensure compliance with AML/CFT regulations. The effective use of financial information and intelligence assists law enforcement in investigating and prosecuting unlawful activities and illicit actors.

Operational Authorities

Operational authorities use different tools, such as imposing financial sanctions that freeze illicit assets, to combat threat actors and protect the U.S. financial system from abuse. Policymakers take a broad view of this system to identify points of strength and weakness and take other actions to address systemic vulnerabilities or challenges.

Recent Developments

In recent years, the United States has made significant progress in creating a centralized database of beneficial ownership information. This initiative aims to mitigate critical vulnerabilities in the financial system and allow operational authorities to conduct more effective investigations and combat illicit finance facilitated by opaque corporate structures.

2024 Strategy: Strengthening the U.S. AML/CFT Regime

The 2024 Strategy builds upon the progress of the 2022 Strategy, identifying the steps necessary to strengthen the U.S. AML/CFT regime so that illicit activity and illicit proceeds generated in the United States or transiting through the U.S. financial system are better detected, reported, and disrupted.

Four Priorities for the 2024 Strategy

The 2024 Strategy sets forth four priorities and 15 associated supporting actions below:

  • Implement the CTA, Provide Authorized Access to BOI, Protect Data, and Promote Compliance
  • Bring Greater Transparency to Real Estate Transactions
  • Assess Need for Additional Action on Sectors Not Subject to Comprehensive AML/CFT Measures
  • Consider Updates to the Regulatory Requirements and Supervisory Framework for Virtual Asset Activities

Priority II: Promote a Risk-Focused and Effective AML/CFT Regulatory Framework for Financial Institutions

  • Assess Potential Need to Revise Recordkeeping and Reporting Requirements and Thresholds
  • Enhance Risk-Focused Supervision and Enforcement
  • Appropriately Resource AML/CFT Supervision and Enforcement for Certain Non-Bank Financial Institutions

Priority III: Enhance Operational Effectiveness in Combating Illicit Finance

  • Regularly Update and Communicate Illicit Finance Risks and National AML/CFT Priorities
  • Prioritize Targeted Measures and Interagency and Multilateral Coordination to Disrupt Illicit Finance Activity
  • Expand and Enhance Public-Private Information Sharing
  • Strengthen Implementation of Global AML/CFT Standards

Priority IV: Support Responsible Technological Innovation and Harness Technology to Mitigate Illicit Finance Risks

  • Support U.S. Leadership in Financial and Payments Technology
  • Encourage Private Sector Use of Technology to Improve AML/CFT Programs and Compliance
  • Continue to Enhance Use of AI, Data Analytics, and Additional Technological Innovations in Government Efforts to Combat Illicit Finance