Davis Polk partner Dan Stipano was recently quoted in VIXIO discussing FinCEN’s list of national anti-money laundering priorities. Dan noted that Congress designed the legislation to move AML examinations away from check-the-box compliance exercises and towards a more risk-based approach that pays more attention to areas in which financial crime is most likely. Dan also noted that because the priorities are very high level, they raise some questions as to how FinCEN expects financial institutions to incorporate them into their AML efforts. Although not all of these priorities will be applicable to all financial institutions, to the extent they are applicable, the bank will be expected to assess the risks and then calibrate their programmes accordingly, Dan explained. 

U.S. Publishes First National AML Priorities,” VIXIO (July 13, 2021) (subscription required)