AML/CFT Treasury Strategy Released


The Treasury Department issued the 2024 National Strategy for Combatting Terrorist and Other Illicit Financing, which provides a blueprint of the U.S. government’s goals, objectives, and priorities to disrupt and prevent illicit financial activities.

The 2024 Strategy addresses the key risks from the 2024 National Money Laundering, Terrorist Financing, and Proliferation Financing Risk Assessments  and details how the United States will build on recent historic efforts to modernize the U.S. anti-money laundering/countering the financing of terrorism (AML/CFT) regime, enhance operational effectiveness in combating illicit actors, and embrace technological innovation to mitigate risks.

“In this critical moment for our national and economic security, we need to continue to close the pathways that illicit actors seek to exploit for their schemes,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “We recognize the threat illicit financial activity represents to our national security, economic prosperity, and our democratic values, and are focused on addressing both the challenges of today and emerging concerns.”

The 2024 Strategy addresses key illicit finance threats related to large-scale fraud schemes, potent ransomware attacks, an opioid-driven overdose epidemic, foreign and domestic terrorist attacks, corruption, and illicit exploitation of technological advances in payments and financial products and services.

The 2024 Strategy identifies four priorities and 15 supporting actions to guide U.S. government efforts. The four priority recommendations are:

1. close legal and regulatory gaps in the U.S. AML/CFT framework that illicit actors exploit to anonymously access the U.S. financial system by operationalizing the beneficial ownership information registry for law enforcement, national security, and intelligence use; finalizing rules related to the residential real estate and investment adviser sectors; and assessing other sectors that may be vulnerable to illicit finance;

2. promote a more effective and risk-focused U.S. AML/CFT regulatory and supervisory framework for financial institutions to make them more efficient and effective in preventing illicit finance by providing clear compliance guidance, sharing information appropriately, and ensuring adequate resourcing for supervisory and enforcement functions;

3. enhance the operational effectiveness of law enforcement, other U.S. government agencies, and international partnerships in combating illicit finance so threat actors cannot find safe havens for their operations; and

4. realize the benefits of responsible technological innovation in the United States by developing new payments technology, supporting the use of new mechanisms for private sector compliance, and utilizing automation and innovation to find novel ways to combat illicit finance.

Rulemaking Sometime...

Jim Richards notes in a blog post on his site that by 2026 FinCEN intends to:

 "issue the NPRM required by AML Act section 6101 to propose updates to the AML program rule requirements to require effective, risk-based, and reasonably designed AML/CFT programs."

Section 6101 of the AML Act of 2020 required a final rule by December 2021. 

"Very simply, section 6101 called for (1) the establishment of national exam and supervision priorities; (2) financial institutions incorporating those priorities into their AML/CFT programs; (3) federal regulators supervising and examining those institutions on whether and how they incorporated the priorities into their programs; and (4) Treasury, through FinCEN, to publish the rules (regulations) needed for all of that to happen," Richards writes.

He also points out the shortcomings in the requisite DOJ statistical reporting as assessed in GAO's March 11, 2024 report “Anti-Money Laundering: Better Information Needed on Effectiveness of Federal Efforts”. 

Click [here] to read the 2024 National Strategy for Combatting Terrorist and Other Illicit Financing.


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