Davis Polk partner Dan Stipano was quoted in MoneyLaundering.com on FinCEN’s plan to formally require financial institutions to assess their exposure to money launderers and other financial criminals and ensure they have an “effective and reasonably designed” AML program in place. Dan noted that non-bank institutions probably lag behind banks in formally assessing their vulnerabilities to financial crime, and a new risk assessment mandate would boost regulators’ enforcement powers for all categories of financial institution. He added that FinCEN’s plan will change risk assessments from a supervisory expectation into a legal requirement that can be directly addressed through enforcement.

“FinCEN Sets Timetable for Mandatory Risk Assessments, ‘Effective’ AML Programs,” MoneyLaundering.com, (January 28, 2022) (subscription required)

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