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ARTICLE · 07 JUNE 2022

FinCEN Weighs Path To A No-Action Letter Process

Morrison Foerster
Morrison Foerster
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The ANPRM follows a 2021 FinCEN assessment and a Report to Congress about the feasibility and usefulness of such a process.

United StatesGovernment, Public Sector
Marc-Alain Galeazzi
Marc-Alain Galeazzi
Jeremy Mandell
Jeremy Mandell
Barbara Mendelson
Barbara Mendelson
Malka Levitin
Malka Levitin
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On Friday, FinCEN published an Advance Notice of Proposed Rulemaking (ANPRM) as it further considers implementing a no-action letter process related to anti-money laundering compliance. The ANPRM follows a 2021 FinCEN assessment and a Report to Congress about the feasibility and usefulness of such a process.

June 2021 – No-Action Letter Report to Congress

Under Section 6305(a) of the Anti-Money Laundering Act of 2020 (AMLA), Treasury's Financial Crimes Enforcement Network (FinCEN) is required to assess whether a no-action letter process should be established for inquiries concerning the application of the Bank Secrecy Act (BSA) and other anti-money laundering (AML) and countering the financing of terrorism (CFT) laws and regulations to specific conduct(s).

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Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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