Wolfsberg responds to the consultation on FinCEN’s notice of proposed rulemaking (NPRM) for the AML/CFT program rule, emphasising the need for greater flexibility in the risk assessment process

They also call for clearer expectations for AML program effectiveness, particularly for U.S.-based management of these programs. Another critical point is the recommendation to extend the implementation timeline for firms, as they believe the current schedule might be too tight for many institutions to comply effectively…