MSBA Comment Letter on ANPR Anti-Money Laundering Program Effectiveness Docket FINCEN-2020-0011
November 16, 2020
This letter is written on behalf of the members and constituents of the Money Services Business Association1 (“MSBA”) regarding Regulatory Identification Number (RIN) 1506- AB44. The MSBA is grateful for the opportunity to provide comments to the Financial Crimes Enforcement Network (“FinCEN”) in response to the Advance Notice of Proposed Rulemaking (“ANPR”) regarding potential regulatory amendments requiring that all covered financial institutions must maintain an "effective and reasonably designed" anti-money laundering program.