MSB Focus: How FinCEN’s “Effective and Reasonably Designed AML” Rule May Impact MSBs
May 26, 2021
12:00PM - 2:00PM ET
FinCEN’s Advance Notice of Proposed Rulemaking regarding “effectiveness” of AML programs shook the compliance world. And though details of what constitutes a “reasonable and effectively designed” AML program aren’t yet known, MSBs will clearly be significantly affected. MSBs already must maintain effective AML programs, but changes FinCEN is considering could redefine the US regulatory regime. The rule contemplates further shifting examinations from a “check-the-box” approach to evaluating MSBs’ AML programs for impact and effectiveness. The rule could reduce compliance burdens by favoring the quality of information in SARs over, say, the quantity of filings. Though FinCEN’s idea to issue “strategic AML priorities” every two years could clarify regulatory expectations, some worry swift pivots may prove costly and cumbersome. Finally, it isn’t certain how the rule might address “de-risking” issues that often get MSBs de-banked. Join this expert-led webinar on what FinCEN’s initiative may mean for MSBs.