The Financial Crimes Enforcement Network (FinCEN) issued the first government-wide priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) policy Wednesday. The priorities identify and describe the most significant AML/CFT threats currently facing the United States. 

FinCEN will issue regulations at a later date to specify how financial institutions should incorporate these priorities into risk-based AML programs, as required by the Anti-Money Laundering Act of 2020.

A complete breakdown can be found on CUNA’s CompBlog.

The priorities, in no particular order are:

• Corruption;
• Cybercrime, including relevant cybersecurity and virtual currency considerations;
• Foreign and domestic terrorist financing;
• Fraud;
• Transnational criminal organization activity;
• Drug trafficking organization activity;
• Human trafficking and human smuggling; and
• Proliferation financing.

FinCEN also issued a joint statement, in coordination with regulators including NCUA, to provide guidance to certain covered financial institutions on the applicability of the priorities before regulations are promulgated.

The statement clarifies that the priorities do not create a requirement to change current AML programs, but recommends credit unions begin to consider how they will incorporate the priorities into the risk-based BSA compliance programs, such as by assessing the potential related risks associated with the products and services they offer, the customers they serve, and the geographic areas in which they operate.

The statement also indicates these priorities will not be included in Bank Secrecy Act examination programs until regulations on how to incorporate them are issued.