What Is an “Effective AML/CFT Compliance Program”?

Perkins Coie – The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism (AML/CFT) compliance program rules for financial institutions and banks effectively covering the eleven industries subject to AML/CFT compliance program requirements under the Bank Secrecy Act (BSA).