As required by the Anti-Money Laundering Act of 2020 (AMLA), the Financial Crimes Enforcement Network (FinCEN) published its first list of priorities for anti-money laundering and countering the financing of terrorism (AML/CTF) policy (Priorities). The AMLA requirement states that FinCEN must establish priorities within 180 days of passing the AMLA. These priorities were published June 30, 2021, highlighting several areas of heightened risk for the U.S. financial system.
The FinCEN priorities somewhat mirror the Financial Action Task Force (FATF) expanded guidance in several critical areas of AML/CFT global concerns, also released on June 30, 2021. FATF is the global watchdog for AML/CFT activity, and it is important to note that the United States shows full support in global efforts by their recent priorities release. The eight Priorities, in no specific order, are as follows:
- Cybercrime, including relevant cybersecurity and virtual currency considerations
- Foreign and domestic terrorist financing
- Transnational criminal organization activity
- Drug trafficking organization activity
- Human trafficking and human smuggling
- Proliferation financing
These Priorities hold no surprises, as most have been addressed in numerous FinCEN advisories. While these are general today, the AMLA requires that regulations be written around each Priority, as appropriate.