Skip to content

Wolfsberg Group response to FinCEN's Proposed AML Program Rule

06 September 2024

Wolfsberg Group response to FinCEN's Proposed AML Program Rule

The Wolfsberg Group published its response to FinCEN’s Consulted Notice of Proposed Rulemaking for the AML Program Rule.

 

Key recommendations to FinCEN include:

  • Provide Maximum Flexibility for Risk Assessment Processes;
  • Revise Requirements for Risk Assessment Processes;
  • Clarify Requirements for U.S.-Based AML/CFT Management;
  • Define Expectations for AML Program Effectiveness; and
  • Significantly Extend the Implementation Time for firms.

Firms can view the Group’s response to the now-closed consultation in advance of potential forthcoming changes to FinCEN rules and requirements
Back to news and insights Read next article