FinCEN’s AML Program Rule Overhaul, Stablecoins, and the 10-Year Legacy of the Panama Papers
In this week’s This Week in AML, Elliot Berman and John Byrne break down FinCEN’s newly released notice of proposed rulemaking to modernize the AML/CFT program rule—its first major rethink in two decades. They explore what a risk-based refocus could mean in practice, including new requirements for risk assessments, changes to the four pillars, examiner discretion, and the unprecedented requirement that bank regulators consult with FinCEN before certain enforcement actions. The conversation also covers a flurry of regulatory and enforcement developments: the OCC’s GENIUS Act proposal on…
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