Treasury Notes

 Continuing to Combat Terrorists and Financial Criminals: The U.S. National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment

By: Jennifer Fowler

This afternoon, Treasury published the U.S. National Money Laundering Risk Assessment and the National Terrorist Financing Risk Assessment.  Given the breadth of issues covered and the significance of these reports, we’d like to take this opportunity to contextualize our efforts, and help readers understand how we expect others to use these national risk assessments.

Why are we doing this? We undertook this review to help ensure the continued effectiveness of our anti-money laundering and countering the financing of terrorism (AML/CFT) framework. The U.S. Government is responsible for developing and enforcing AML/CFT policy.  However, the strength of our framework to detect and deter illicit finance depends on whether industry stakeholders can effectively implement those policies – information about illicit methods, their impacts, and enforcement efforts is critical to helping them do this.  These risk assessments are one such source of information, meant to support our partners in both the public and private sectors as they develop programs to manage and combat relevant illicit finance risks.

What are these assessments?  These assessments represent thorough work by the Treasury Department and the interagency to synthesize all relevant information and develop a comprehensive view of the illicit finance threats, vulnerabilities, and risks facing the U.S. financial system.  We hope that financial institutions and other stakeholders will use these assessments, in concert with other information sources, to bolster their understanding of the illicit finance risks they face.  Doing so should better enable stakeholders to implement AML/CFT programs in line with the “risk-based approach” – a method for identifying, assessing and understanding the risks to which they are exposed and taking proportional measures to address them.

…and what are they not?  These assessments are not intended to be the sole source of information that stakeholders use as they develop their compliance efforts.  While our assessments contain a great deal of valuable information, there is no silver bullet in AML/CFT. Criminals will continue to develop new money laundering methods that are not addressed in these pages.  And some of the information in our assessments will not apply to every U.S. financial institution.  We expect institutions to identify and manage their own risk.

What does the U.S. Government plan to do with this information? We expect U.S. financial institutions to remain vigilant in the fight against money laundering and terrorist financing – and we hold ourselves to the same high standards.  We will use the information in these assessments to continue to adjust or develop policies to ensure that we continue to effectively combat money laundering and terrorist financing.  And this information will be used as we continue to adjust our regulations to close any vulnerabilities we identify; one such example is our ongoing customer due diligence rulemaking.  Furthermore, we will remain unrelenting about identifying, assessing, and communicating the illicit finance issues that exist so that we can continue to make the U.S. financial system more safe and secure.

Jennifer L. Fowler is the Deputy Assistant Secretary for Terrorist Financing and Financial Crimes at the U.S. Department of the Treasury.​ 

Posted in:  National Money Laundering Risk Assessment
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