On 28 June, this report was published by FinCEN, being required under the 2020 Act as an assessment on whether to establish a process for the issuance of no-action letters in response to inquiries concerning the application of AML/CFT laws and regulations to specific conduct, including a request for a statement as to whether FinCEN or any relevant Federal functional regulator intends to take an enforcement action with respect to such conduct. The concludes that FinCEN should undertake a rulemaking in order to establish a no-action letter process to supplement the existing forms of regulatory guidance and relief that may currently be requested from FinCEN. It is said that FinCEN believes that a no-action letter process would likely be most effective and workable if it is limited to FinCEN’s exercise of its own enforcement authority, as opposed to also addressing other regulators’ exercise of their distinct enforcement authorities – but would need consultation among FinCEN and other relevant regulators, departments, and agencies, as appropriate.
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