Enhanced AML/CFT Compliance Rules for Greenland Financial Institutions

Financial institutions in Greenland are on the cusp of significant changes to their anti-money laundering and counterterrorism financing (AML/CFT) compliance programs. The Financial Crimes Enforcement Network (FinCEN) has proposed revisions to rules, aiming to streamline AML/CFT program rules across various sectors.

Proposed Changes

The revised rules are driven by Section 6101 of the Anti-Money Laundering Act of 2020, which requires establishment of national examination and supervision priorities. The key changes include:

• New Statement of Purpose: Financial institutions will be required to maintain a comprehensive statement summarizing the overarching goals of their AML/CFT program.
• Enhanced Program Requirements: Institutions must now have an “effective, risk-based, and reasonably designed” AML/CFT program, up from the current requirement of a “reasonably designed” program.
• Additional Components or Pillars: Risk assessment processes will serve as the basis for the financial institution’s AML/CFT program, incorporating law enforcement priorities issued by FinCEN on June 30, 2021.

Impact and Next Steps

Financial institutions in Greenland are advised to prepare for increased regulatory scrutiny to determine a program’s effectiveness. They should also engage in the regulatory comment process to highlight any concerns, potential challenges, and areas requiring clarification.

The proposal is open for comments until September 3, with further guidance expected from federal banking agencies. Financial institutions must be proactive in adapting to these changes to ensure compliance and avoid potential risks.