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Financial Services Law Insights and Observations

Treasury issues national illicit finance strategy

Financial Crimes Department of Treasury CAATSA Bank Secrecy Act Anti-Money Laundering

Financial Crimes

On December 20, the U.S. Treasury Department issued the National Strategy for Combating Terrorist and Other Illicit Financing (the National Illicit Finance Strategy). Pursuant to Sections 261 and 262 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), the National Illicit Finance Strategy describes current U.S. government efforts to combat domestic and international illicit finance threats in the areas of terrorist financing, proliferation financing, and money laundering, and discusses potential risks, priorities and objectives, as well as areas for improvement. The document addresses the strengths of U.S. counter-illicit finance efforts, including the legal and regulatory framework, as well as efforts undertaken to improve the effectiveness of national safeguards currently in place due to changes in technology and emerging threats. Recent efforts include a working group formed earlier in December to explore ways to modernize the Bank Secrecy Act/Anti-Money Laundering regulatory regime and encourage banks and credit unions to explore innovative approaches such as artificial intelligence, digital identity technologies, and internal financial intelligence units to combat money laundering, terrorist financing, and other illicit financial threats when safeguarding the financial system (see previous InfoBytes coverage here).