On June 30, 2021, FinCEN issued its list of priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) (the Priorities) as required by the Anti-Money Laundering Act. The Priorities are intended to identify and describe the most significant AML/CFT threats facing the United States. The Priorities – listed, according to FinCEN, “[i]n no particular order” – are as follows:
- Domestic and international terrorist financing
- Transnational criminal organizations
- Drug trafficking organizations
- Human trafficking and human smuggling
- Proliferation financing
The federal regulatory agencies, along with FinCEN issued statements emphasizing that these Priorities will require regulations before they go into effect and that no institution will be examined for them until such time. However, institutions are reminded that there are existing regulations, advisories and guidance in place that institutions must continue to follow.