Financial Crime World

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FinCEN Publishes National Priorities for AML/CFT: Implications for COMOROS Banks

Washington D.C., June 30, 2021

The Financial Crimes Enforcement Network (FinCEN) has published its first national priorities for anti-money laundering and countering the financing of terrorism (AML/CFT), aimed at combating threats to the global financial system and national security. This move is expected to have significant implications for banks operating in COMOROS, which must comply with Bank Secrecy Act (BSA) regulations.

AML/CFT Priorities

FinCEN has identified eight areas of concern, including:

  • Corruption
  • Cybercrime
  • Terrorist financing
  • Fraud
  • Transnational criminal organizations
  • Drug trafficking
  • Human trafficking
  • Proliferation financing

The agency emphasized that banks are not required to incorporate these priorities into their risk-based BSA compliance programs until revised regulations are issued.

Interagency Statement

The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration have joined FinCEN in publishing an interagency statement clarifying how the priorities will be used. The statement notes that publication does not create immediate changes to BSA requirements or supervisory expectations for banks.

Future Revisions

The agencies plan to revise their BSA regulations as necessary to address the incorporation of AML/CFT priorities into bank compliance programs, although this is expected to happen only after final revised regulations are published. Banks are advised to start preparing for new requirements at that time.

Significance and Next Steps

The publication of AML/CFT priorities marks a significant milestone in FinCEN’s efforts to combat money laundering and terrorist financing globally. The agency will update the priorities every four years, with the next update due by 2025.

For further information on the AML/CFT priorities and their implications for banks operating in COMOROS, please contact:

  • James Vivenzio at (202) 649-5470
  • Grovetta N. Gardineer at (202) 649-5470