FinCEN's 2024 Priorities: What Regulated Businesses Need to Know

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.

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.

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.

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.

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.