The Clearing House (TCH) released a report entitled A New Paradigm: Redesigning the U.S. AML/CFT Framework to Protect National Security and Aid Law Enforcement. The paper analyzes the current effectiveness of the AML/CFT regime, identifies fundamental problems with that regime, and proposes a series of reforms to remedy them.
The report reflects conclusions reached in two closed-door symposia, in April and October 2016, that convened approximately 60 leading experts in this field. The group included senior former and current officials from law enforcement, national security, bank regulation and domestic policy; leaders of prominent think tanks in the areas of economic policy, development, and national security; consultants and lawyers practicing in the field; FinTech CEOs; and the heads of AML/CFT at multiple major financial institutions. The first meeting focused on problems with the current regime; the second focused on a review of potential solutions. The conclusions on both are set forth in the report.