The US Institute of International Bankers submitted comments supporting the Federal Reserve’s proposed modernization of anti-money laundering and countering the financing of terrorism program requirements. It backed a more risk based framework that allows banks to focus resources on higher risk activities, while calling for greater alignment between regulatory requirements and supervisory expectations. The institute asked the Federal Reserve to define the significant or systemic implementation failures that could trigger enforcement or major supervisory action and distinguish them from isolated, technical or immaterial deficiencies. It also sought confirmation that the policy would cover all Federal Reserve supervised institutions, including foreign banking organizations, and preserve firms’ discretion to tailor risk assessments and resources to their risk profiles. Other recommendations include accommodating artificial intelligence and other compliance technologies without imposing additional risk solely because of their use, recognizing support from non-US personnel and third parties where the designated AML/CFT officer is US based, and providing a 24-month implementation period after the final rule is issued.
2026-09-08Institute of International Bankers
US Institute of International Bankers backs risk based AML and CFT reform, seeks clearer supervisory and enforcement standards
The US Institute of International Bankers backed the Federal Reserve’s proposed risk based AML/CFT framework but called for clearer and more consistent supervisory and enforcement standards. It sought explicit coverage of foreign banking organizations, flexibility for firm specific risk judgments and technology use, and a 24-month implementation period following the final rule.