Submission of comment letter on FinCEN’s Notice of Proposed Rulemaking (“NPRM”) to strengthen and modernize financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs pursuant to the Anti-Money Laundering Act of 2020
Dear FIBA members,
On September 3, 2024, FIBA submitted a comment letter (“Comment Letter”) to the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) to respond to the questions FinCEN presented in the NPRM, and submit proposals for language revisions to the text of the proposed amendments to the AML program rules for banks outlined in 31 C.F.R. § 1020.
The Comment Letter was the result of the joint efforts of our Legal & Regulatory Affairs (“LARA”) and AML Compliance committees. The Comment Letter is divided into two sections. Section I expresses FIBA’s responses to the specific questions presented in the NPRM. Section II contains FIBA’s proposed language revisions to the proposed amendments to 31 C.F.R. § 1020, with explanatory comments.
A big shoutout to Peter Rahaghi of Shutts & Bowen for taking the lead on drafting the letter, and to Marina Olman of Greenberg Traurig, Carl Fornaris of Winston & Strawn, Harry Cupp of Sunwest Bank, Juan Carlos Ariza of Davivienda International, and Daniel Gutierrez of Ocean Bank, for their significant contributions.
As you will see from the 34 pages, this was no small undertaking and we appreciate their time and effort on this important topic that will impact our industry!
Regards,
David Schwartz
CEO & President