On Nov. 16, BPI submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) on its proposed definition of AML program effectiveness. The letter recommends that FinCEN, in coordination with other regulatory agencies, provide institutions the flexibility to design AML programs that align with their business models. This flexibility, coupled with regulatory reforms, would empower banks to devote additional resources to working with law enforcement to address more serious crimes and would improve the utility of the information available to the law enforcement and intelligence communities. “Modifying the existing AML program requirements to allow for greater flexibility, clarity and coordination among agencies will dramatically improve effectiveness and benefit both the U.S. financial system and national security,” Angelena Bradfield, SVP of AML/BSA, Sanctions & Privacy at the Bank Policy Institute, said in a BPI statement Nov. 17. BPI and a coalition of financial trades also submitted an accompanying letter to FinCEN emphasizing many of these recommendations.
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