On 17 September, KYC 360 reported an American Banker report that FinCEN has said that it plans to firm up the definition of an “effective and reasonably designed” AML compliance programme, something the regulator said had “no specific, consistent definition in existing regulation”.  FinCEN is also mulling whether it should play a more active role in guiding the priorities of financial institutions with AML compliance requirements.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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