Industry-Wide

In June 2021, FinCEN identified and published national AML/CFT priorities for financial institutions, a significant development under the Anti-Money Laundering Act of 2020. The priorities identified key threats including corruption, cybercrime, terrorist financing, fraud, and proliferation financing, among others. Financial institutions, including banks engaged in fintech partnerships and BaaS arrangements, were expected to incorporate these priorities into their Bank Secrecy Act compliance programs. The guidance was particularly relevant to BaaS and sponsor banks, which face elevated AML risks due to their reliance on fintech partners for customer onboarding and transaction monitoring. Regulators subsequently began examining institutions for compliance with these priorities during supervisory reviews.

Verified from source: FinCEN issued on June 30, 2021 the first government-wide list of AML/CFT priorities as required by the Anti-Money Laundering Act, identifying eight priority areas. Regulators will review and examine financial institutions in part according to how their AML/CFT compliance programs incorporate and further the Priorities.