The Institute of International Finance (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.
“We believe the focus of the Consultation on effectiveness is critical and timely. The current global framework for fighting financial crime is not as effective as it could be, and more needs to be done at the international, regional, and national levels to help identify and stem the flow of illicit finance. We agree that changes which help modernize the regulatory regime to address the evolving financial crime threats and provide financial institutions with greater flexibility in the allocation of resources will result in the enhanced efficacy and efficiency of financial crime risk management programs.”