In the FinCEN publication of AML Priorities, Wolfsberg’s Efficiency Measures, A Snapshot of the Future of Financial Crime Compliance – CFCS


By Brian Monroe
[email protected]
July 14, 2021

The Future of Financial Crime has “effective” compliance teams generating “very useful” and “relevant” intelligence for investigators in targeted and changing “priority areas”. both large generators of illicit income, such as corruption and computer fraud, but also listening to the actions and reactions of international groups of threatening actors.

These are just a few of the key takeaways from the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) which publishes the official list of its national priorities for combating money laundering and terrorist financing (AML / CFT), a collection of historical pushbacks like organized crime groups and other growing risks, like record-breaking ransomware attacks and crypto-fueled paydays.

The widely watched and eagerly awaited AML priorities are the first concrete update to implement the US Anti-Money Laundering Law (AML Act) – the most significant upgrade to the country’s financial crime framework since the USA Patriot Act of 2001.

AMLA is a broad set of updates to break down beneficial ownership strongholds, strengthen public-private information sharing, usher in a new era of innovation, and focus on efficiency – with the threat of more sanctions. high in cases of violation and serial misdemeanors.

To read ACFCS’s coverage of the anti-money laundering law, which Congress enacted in January after overturning a presidential veto, click here.

Coinciding with and underpinning the publication of FinCEN’s anti-money laundering priorities, the Wolfsberg Group issued a critical missive to detail the practical and tactical steps of how financial institutions can actually demonstrate their effectiveness, a term used in recent years with much fanfare, but little in terms of clear and verifiable limits.

In short, Wolfsberg’s efficiency measures include:

  • Do you comply with local anti-money laundering laws and know global standards?
  • Do you produce information that is very useful for law enforcement, guided by national AML priorities?
  • Do you have a reasonable compliance program that examines internal and external threats, gaps and vulnerabilities and adjusts for increasing or decreasing risk and law enforcement contributions?

To read the full statement from the Wolfsberg Group, an influential alliance of more than a dozen of the world’s largest banks, including Citi, JPMorgan, Barclays, Credit Suisse and others, click here.

FinCEN’s priorities, probably familiar drumbeats for the big international banks, receive ever more weight and attention as they stand at the forefront of the new vanguard of the fight against crime, the cutting edge of crime. launches for financial crime fighters, not buried in dense and didactic reports, such as like Treasury 2020 illicit financing strategy, 2018 national risk assessment and others.

FinCEN’s stated anti-money laundering priorities are:

  • Corruption;
  • cybercrime, including relevant cybersecurity and virtual currency considerations;
  • financing of foreign and domestic terrorism;
  • fraud;
  • transnational criminal organization activity;
  • drug trafficking organization activity;
  • trafficking in human beings and trafficking in human beings; and
  • proliferation financing

To read the full list of AML priorities and associated interagency statements, click here.

Together, the priorities and efficiency measures provide a glimpse into the future of the fight against financial crime.

A better future where banks will not be so divided against themselves between following the letter of the law – the process, the glitz around managing risk management to manage risk – and the spirit of the law: stop illicit cabals from all stripes by choking their financial blood.

“Really, for the first time in US history, we have a set of AML priorities for the regime to focus on and a set of financial crime priorities to focus on,” Craig Timm said. , Managing Director and Head of Financial Crime Compliance at Bank. from America, in a social network assignment.

“It’s a huge achievement for FinCEN and the other agencies to achieve this. ”

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