FinCEN Issues AML Priorities


Alvaro Soto

Publish Date


Compliance Alert

  • AML and Financial Crime

On June 30, 2021, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) published its first government-wide priorities for AML (the “Priorities”), a mandate established by the AML Act of 2020 passed by US Congress earlier this year.

The Priorities are intended to assist financial institutions in their efforts to meet their obligations under regulations designed to combat money laundering and counter terrorist financing. The Priorities mostly put the industry on notice, noting that FinCEN will issue regulations at a later date to specify how institutions incorporate relevant Priorities into their AML programs, acknowledging an expectation of a risk-based approach and that not all Priorities are relevant to all financial institutions.

The Priorities, which FinCEN indicates are in no particular order are:

  • Corruption
  • Cybercrime
  • Foreign and Domestic Terrorist Financing
  • Fraud
  • Transnational Criminal Organization Activity
  • Drug Trafficking Organization Activity
  • Human Trafficking
  • Proliferation Financing

FinCEN’s accompanying statements on the Priorities make clear of the participation of other regulators like the SEC and CFTC, and the applicability of the Priorities to non-bank financial institutions, such as broker dealers, mutual funds, and futures commission merchants and introducing brokers in commodities.

ACA guidance

As noted by the Priorities, financial institutions may wish to start considering how they will incorporate the Priorities into their risk-based AML programs, like assessing the potential risks associated with the products and services they offer, the customers they serve, and the geographic areas in which they operate.

How we help

Our AML and Financial Crimes practice offers advisory services and solutions to assist financial services firms in addressing financial crimes-related threats and regulatory concerns. Specific areas include AML, Foreign Corrupt Practices Act (FCPA) and Anti-Bribery, and cybersecurity services.

We work with investment advisers, private funds and Securities Financial Institutions in risk assessing, developing policies and procedures, and performing independent tests or gap analyses of their AML Programs.

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If you have any questions about this or how ACA can support you to meet your regulatory obligations, please reach out to your ACA consultant or contact us here.