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Compliance and Regulatory Alerts  |  10-21-21

FINRA Warns Firms to Pay Attention to FinCEN AML Priorities

On October 8, 2021, FINRA urged member firms to review and update their Anti-Money Laundering (“AML”) compliance programs (under Rule 3310) in light of the Financial Crimes Enforcement Network’s (“FinCEN’s”) recently published priorities on the subject. FinCEN came out with those priorities (and an accompanying statement) on June 30, 2021 (see Bates’ post), in accordance with AML Act of 2020 (“AMLA”), which became law on January 1, 2021. The AMLA updated the Bank Secrecy Act (“BSA”), the overarching law for countering money laundering and terrorism financing (see Bates’ post).

The FinCEN priorities are not new and cover areas such as fraud and cybercrime that are the subject of frequent advisories and updated guidance. (For example, FinCEN just issued an analysis on ransomware trends identified in BSA data pursuant to AMLA.)  Consistent with the June 2021 FinCEN statement, FINRA said that it wants to see how firms are beginning to incorporate and document the FinCEN priorities, including the latest specific updates, into their risk-based compliance programs.

FINRA suggested that firms assess risks and update red flags already contained in their programs and consider “risks presented by factors such as their business activities, size, the geographic locations in which they operate, the types of accounts they maintain, and the types of transactions in which they and their customers engage.” FINRA also suggested reviewing and updating related technologies for monitoring and investigating suspicious activity that would be relevant to the FinCEN priorities. The regulator said that currently FinCEN priorities don’t change the supervisory expectations for firms. However, FINRA noted that FinCEN is working to develop and publish final guidance and regulations that will detail “how financial institutions should incorporate the AML/CFT priorities into their risk-based AML programs.”

How Bates Helps

Bates AML and Financial Crimes helps its clients meet their AML/CFT obligations through experience, resources, and ongoing guidance. We work within the U.S. and internationally, with a European partner firm offering artificial intelligence and AML optimization for projects. Bates is a practitioner-led firm, consisting of former Chief AML Officers and Chief Compliance Officers, former regulators and practicing attorneys, Risk Management Officers, as well as data and technology specialists to deliver exceptional results on a cost-effective basis.

Our AML and Financial Crimes services include:

  • AML gap assessments and audits
  • BSA/AML and OFAC risk assessments
  • AML program design and implementation
  • Customer risk model design, tuning and implementation
  • KYC system design, testing and implementation
  • AML transaction monitoring and sanctions system tuning, testing and new platform implementation or existing platform upgrades
  • Staffing support for KYC, name screening, transaction monitoring backlogs and lookbacks
  • Model validations
  • Coverage assessments
  • AML Compliance for Cryptocurrency
  • Money Transmitter Licensing
  • Artificial Intelligence and Big Data analytics support
  • Independent consulting review for AWC or other regulatory response
  • AML and Financial Crimes testimony
  • AML and Financial Crimes corporate training

For questions concerning our AML and Financial Crimes services, AMLA, and how it may impact your business and AML obligations, please reach out to us at:

For additional information, please follow the links below to Bates Group’s Practice Area pages:

Bates AML and Financial Crimes

Bates Compliance

Regulatory and Internal Investigations

Consulting and Expert Testimony

Retail Litigation and Consulting

Contact Bates Group

Bates Group is with you every step of the way. Contact us today for more information on how our End-to-End Solutions can help your firm.