Federal Banking Agencies and FinCEN Hit Reset on AML/CFT: Implications for Financial Institutions

Risk-based resource allocation becomes the regulatory standard. Both the Office of the Comptroller of the Currency (OCC), jointly with the Federal Deposit Insurance Corporation (FDIC) and National Credit Union Administration (NCUA), and FinCEN have issued proposed rules that would explicitly require financial institutions to direct more attention and resources toward higher-risk customers and activities—and away from lower-risk ones—marking a significant shift from “check-the-box” compliance to... By: Perkins Coie