FinCEN publishes national AML/CFT priorities that signal where regulatory attention and enforcement resources will be focused. Here's what the 2024 priorities mean for your compliance program.
National AML/CFT priorities must be incorporated into risk assessments and AML programs - it's a compliance obligation
FinCEN is required by the Anti-Money Laundering Act of 2020 to publish national AML/CFT priorities every two years. These priorities are not just informational - they create a compliance obligation. Covered financial institutions must incorporate the national priorities into their risk assessments and AML programs. A program that doesn't address the published priorities is, by definition, incomplete.
Current priorities include corruption, cybercrime, fraud, drug trafficking, and human trafficking
The current national priorities include: corruption, cybercrime, foreign and domestic terrorist financing, fraud, transnational criminal organization activity, drug trafficking organization activity, human trafficking and human smuggling, and proliferation financing. Each of these priorities has specific implications for different types of financial institutions, and the relevance of each priority to your business depends on your specific risk profile.
Fraud, cybercrime, and drug trafficking are the most immediately relevant priorities for most small businesses
For most small and mid-sized financial businesses, the most immediately relevant priorities are fraud, cybercrime, and drug trafficking. Fraud-related money laundering - including business email compromise, elder fraud, and romance scams - generates significant transaction volume through community financial institutions and MSBs. Cybercrime proceeds are increasingly moved through virtual currency and payment platforms. Drug trafficking proceeds remain a primary driver of cash-intensive money laundering activity.
Risk assessments must explicitly evaluate exposure to each priority area and document the assessment
Incorporating the national priorities into your risk assessment means explicitly evaluating your exposure to each priority area and documenting your assessment. For priorities that are relevant to your business, your risk assessment must describe the specific ways your products, customers, or geography create exposure to that priority area, and the controls you have in place to mitigate that exposure. For priorities that are not relevant, your assessment should briefly explain why.
Training content must be updated to address the national priorities relevant to your business
The practical implication for training programs is that training content must address the national priorities. If your training program was developed before the current priorities were published, it may not address all of the required areas. Review your training content against the current priorities and update it to ensure that your staff understands the specific typologies associated with each priority area that is relevant to your business.
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BSA/AML Principal Consultant · Soflo Consulting
Elena Vargas is a BSA/AML Principal Consultant at Soflo Consulting with over a decade of experience building and auditing compliance programs for regulated businesses across the United States. She specializes in enforcement action remediation, risk assessment development, and examination preparation for money services businesses, mortgage lenders, and fintech companies.
5 sections
Key Takeaways
- 1National AML/CFT priorities must be incorporated into risk assessments and AML programs - it's a compliance obligation
- 2Current priorities include corruption, cybercrime, fraud, drug trafficking, and human trafficking
- 3Fraud, cybercrime, and drug trafficking are the most immediately relevant priorities for most small businesses
- 4Risk assessments must explicitly evaluate exposure to each priority area and document the assessment
- 5Training content must be updated to address the national priorities relevant to your business
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