Things are changing. What do you need to know about AML/CFT National Priorities?
On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) issued the first government-wide priorities for anti-money laundering and countering the financing of terrorism (AML/CFT). These priorities identify the highest-risk threats to institutions. By listing out these priorities, FinCEN is able to assist financial institutions focus on these high-risk areas. The priorities are in no particular order. FinCEN will issue regulations at a later date as to how to financial institutions are to incorporate these priorities into their existing AML programs.

Corruption
The first priority is domestic and international corruption. Corruption weakens democracies and economies by perpetuating conflict and threatening the national security of a nation. Bad actors may take advantage of vulnerabilities in a financial institution to launder funds obtained through illicit activities. Addressing the money laundering risks associated with both domestic and international corruption will help mitigate such actions.
Cybercrime
The second AML/CFT national priority posed by FinCEN is cybercrime. The most renowned forms of cybercrime are threats like phishing, social engineering, and network attacks. Cybercriminals pose a significant threat to financial institutions; they target financial systems to gain access to client and institution private information. FinCEN is interested in the misuse of virtual assets for illegal activities.
Terrorist Financing
Both domestic and international terrorist groups are a focus for FinCEN. Terrorists require funding through illicit activities to conduct operations and other activities, such as the recruitment of new members.
Fraud
The majority of money laundering comes from fraudulent activity, such as romance scams or healthcare scams, such as COVID-19 benefit-related schemes.
Transactional Criminal Organization Activity
Organizations involved in criminal activities, such as human trafficking or weapons smuggling, is of priority to FinCEN.
Drug Trafficking Organization Activity
Illegal drugs continue to generate significant illegal proceeds for drug trafficking organizations. The proceeds, as well as the drugs, may be laundered into the United States.
Human Trafficking & Human Smuggling
As FinCEN notes, financial activity through human trafficking can intersect with the financial system at any time through the process. Human trafficking groups launder funds in a variety of ways, from cash smuggling by a victim to the movement of large amounts of illegal proceeds through shell corporations.
Proliferation Financing
Funds used in connection with the purchase or sale of weapons of mass destruction is the final priority from FinCEN. Financial institutions are vulnerable to the transfer of illicit funds through shell companies.
In Closing
As stated above, FinCEN has stressed that until regulations have been finalized, institutions do not have to incorporate these AML/CFT priorities into their existing AML programs. However, once the regulations have been implemented, institutions should be prepared to demonstrate the processes they do to address these priorities.

About the Author
Rachel Davis
Product Manager at OnCourse Learning
Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.

About the Author
Rachel Davis
Product Manager at OnCourse Learning
Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.
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