The Situation: The U.S. Department of the Treasury’s Office of Financial Crimes Enforcement Network (“FinCEN”) issued the first national policy priorities for anti-money laundering and countering the financing of terrorism (“AML/CFT Priorities”).

The Result: FinCEN and federal and state financial institution regulators (the “Agencies”) have stated they will issue revised regulations within the next six months addressing how to integrate the national policy priorities into risk-based Bank Secrecy Act (“BSA”) and AML/CFT compliance programs.

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