Washington, D.C. – The Charity & Security Network (C&SN) submitted input to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) notice of proposed rulemaking (NPRM) “to strengthen and modernize financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs.” Find the proposed rule, FinCEN Fact Sheet, and announcement.
C&SN’s submission made recommendations on the following:
- Language on De-risking and Financial Inclusion;
- Financial Institutions Must take Non-profit Organization’s Accurate Risk Profiles
- into Account as Part of Upholding the Risk-based Approach;
- Developing and Implementing Examiner Training;
- Risk Assessment Process;
- Feedback Loops;
- Innovation.
Read the full submission here.