FinCEN Seeks Feedback on Plan to Issue No-Action Letters

As part of its execution of the Anti-Money Laundering Act of 2020, the Financial Crimes Enforcement Network on Friday looked for public feedback on a brand-new procedure for providing no-action letters. Federal firms might utilize no-action letters as a kind of enforcement discretion about a particular practice, policy or item that it formalizes in a letter to the entity requesting it; they have actually been utilized in the past to assist in development efforts at managed entities. “A no-action letter process has the potential to spur innovation and enhance overall effectiveness of the AML/CFT framework and the implementation of financial institutions’ compliance programs,” stated FinCEN Acting Director Him Das.

The advance notification of proposed rulemaking looks for discuss whether FinCEN must release no-action letters and, if so, how the procedure ought to work. Specifically, FinCEN inquired about FinCEN jurisdiction, modifications in situations, cancellations, rejection, privacy and assessment requirements. Comments on the notification are due by August 6.


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