FinCEN and Banking Agencies Announce Support for Innovation in BSA/AML Compliance

FinCEN and Banking Agencies Announce Support for Innovation in BSA/AML Compliance


By: V. Gerard (Jerry) Comizio, Michael T. Gershberg, Nathan S. Brownback

On December 3, 2018, the federal banking regulators and the Treasury Department's Financial Crimes Enforcement Network (“FinCEN”) issued a joint statement (the “Statement”) encouraging banks to adopt innovative technological approaches to comply with the requirements imposed on them pursuant to the Bank Secrecy Act (“BSA”) and other anti-money laundering (“AML”) laws and related regulations. The Statement does not impose any new obligations, but instead provides some degree of regulatory comfort for banks that seek to reduce costs and/or improve their compliance systems by trying new approaches to meet their BSA/AML compliance obligations, provided they continue to comply with BSA/AML requirements in accordance with their safety and soundness obligations.

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