ICBA strongly urges FinCEN to adopt the following changes and clarifications in any final rule to ensure the framework is workable, risk-based, and appropriately tailored for community banks:

• Preserve the proposal’s risk-based approach and allow institutions to shift more resources to higher-risk areas and away from lower risk activities.
• Clarify that an effective program need not be perfect and that minor or technical deficiencies do not constitute program failure.
• Confirm that community banks may use streamlined, relationship-based risk assessment processes suited to their size, complexity, and risk profile.
• Revise the AML/CFT Priorities requirement so it does not become an open-ended compliance exercise disconnected from a bank’s actual risk profile.

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