This week, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published an Advance Notice of Proposed Rulemaking (“ANPRM”) soliciting public comment relating to potential amendments to FinCEN’s anti-money laundering (“AML”) regulations. In particular, FinCEN is seeking comment on whether the agency should (1) clearly define an “effective and reasonably designed” AML program; (2) require that all covered institutions conduct AML compliance risk assessments; and (3) regularly publicize national AML priorities. This is potentially a very significant development for the financial services industry and represents an effort by FinCEN to obtain input from all types and sizes of covered financial institutions, including banks, broker dealers, money services businesses, casinos, cryptocurrency exchanges, and more.
