MSB/FinTech Focus: Assessing the Impact of FinCEN’s “Effective and Reasonably Designed AML” Rule
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 and financial innovators in the burgeoning FinTech sectors 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 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 result in de-banking decisions. Join this expert-led webinar on what the initiative may mean for MSBs and FinTech entities.
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