FinCEN Issues Government-Wide AML/CFT Priorities: Four Things To Know

On Wednesday, June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”) released its first set of government-wide priorities for anti-money laundering and countering the financing of terrorism (“AML/CFT”) (the “Priorities”). The release identifies eight priorities, covering money laundering related to: (i) corruption and kleptocracy; (ii) cybercrime, including as it relates to cybersecurity and virtual currency; (iii) international and domestic terrorist financing; (iv) fraud; (v) transnational organized crime; (vi) drug trafficking; (vii) human trafficking and smuggling; and (viii) arms proliferation.

FinCEN developed the Priorities pursuant to Section 6101 of the Anti-Money Laundering Act of 2020 (“AMLA”), which required FinCEN to establish AML/CFT priorities on which financial institutions could rely in allocating resources within their own AML programs. As required by the AMLA, FinCEN consulted with the federal banking agencies and the U.S. Department of Justice, among other government agencies, prior to publishing the Priorities.

This alert summarizes four key takeaways from the Priorities.