IIF Authors

Status: Will be live at 11/17/2020 09:48

IIF Comments on FinCEN AML Program Effectiveness ANPR

The IIF has provided comments on the US Financial Crimes Enforcement Network (FinCEN) Advanced Notice of Proposed Rulemaking (ANPR) on AML Program Effectiveness. The IIF response reflects discussion on the FATF focus on effectiveness, the importance of cross agency and cross border cooperation and the importance of aligning the US reform effort with other jurisdictional work on systemic effectiveness in AML/CFT.