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FinCEN Issues First National AML/CFT Priorities: Crypto at Top of the List

On June 30, FinCEN issued its first ever list of priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) policy. These Priorities are intended to assist financial institutions in their efforts to meet their AML/CFT obligations. The final revised regulations are set to come out within the next 180 days, as required by the Anti-Money Laundering Act of 2020 (AML Act). Most notable in FinCEN’s list were that:

  • The new priorities explicitly include the use of cryptocurrency for ML/TF and ransomware payments
  • Banks are not required to incorporate the AML/CFT Priorities into their risk-based BSA compliance programs until the effective date of the final revised regulations
  • Nevertheless, in preparation for any new requirements when those final rules are published, banks may wish to start considering how they will incorporate the priorities

The full list of priorities are listed, in no particular order, below: While virtual assets are only listed in the second point, cryptocurrency touches each and every one of the eight priorities highlighted by FinCEN.

  1. corruption;
  2. cybercrime, including relevant cybersecurity and virtual currency considerations;
  3. foreign and domestic terrorist financing;
  4. fraud;
  5. transnational criminal organization activity;
  6. drug trafficking organization activity;
  7. human trafficking and human smuggling; and
  8. proliferation financing.

The full press release can be found here:

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