The 26 questions in Tuesday’s request seek information on how FinCEN can better identify and respond to financial crime threats, ensure that BSA reporting and recordkeeping requirements are highly effective in identifying and countering financial crimes and are not outdated or redundant, and improve efficiency in identifying such threats in light of innovative approaches and new technologies. According to the request, “FinCEN is particularly interested in new and innovative approaches to [BSA] compliance that promote a risk-based approach to protecting the financial system from threats to national security posed by various forms of financial crime.”
Comments received in response to Tuesday’s request could lead to new or amended rules and requirements. In addition, they will support FinCEN’s “ongoing formal review” of BSA regulations and guidance required under the Anti-Money Laundering Act of 2020 and will inform a related report that Secretary Yellen must submit to Congress by January 1, 2022. We will continue to keep you updated on the Treasury’s new and increased focus on anti-money laundering efforts.