FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs

Business Better

This episode features a discussion with Nick St. John, Director of Federal Compliance at America’s Credit Unions. We discuss the Notice of Proposed Rulemaking issued by FinCEN and federal banking regulators regarding the enhancement and modernization of anti-money laundering/countering the financing of terrorism (“AML/CFT”) compliance programs under the Bank Secrecy Act (“BSA”). This discussion focuses on the risk assessment process, the NPRM’s impact on the industry, “de-risking” strategies, technological innovation, feedback from law enforcement on the utility of BSA filings, hiring qualified compliance officers, and what it means for an AML/CFT program to be “effective.”

Peter Hardy, partner and co-leader of Ballard’s AML Team leads the discussion. He is joined by Kaley Schafer, also a member of the AML Team and an associate in the firm’s business and transactions department.