In accordance with the Anti-Money Laundering Act of 2020, FinCEN in June 2021 issued the first government-wide statements identifying and prioritizing the most significant AML/CFT threats, including corruption, cybercrime, fraud, transnational criminal organizations, drug trafficking, and human trafficking and smuggling. In January 2022, a Treasury rulemaking agenda published in the Federal Register underscored the breadth and seriousness of regulatory oversight in these areas. Partner David Sullivan comments that military and geopolitical conflicts are a new lens through which to view money laundering and an area in which financial institutions must remain vigilant, pointing out that the 2020 law directs financial institutions to focus on “higher-risk customers,” consistent with an institution’s risk profile. The high-risk designation may take new shape, given events abroad.
3.25.2022