ICBA submitted a letter to the Federal Reserve regarding its proposed amendments to anti-money laundering and countering the financing of terrorism program requirements for banks.

ICBA expressed support for a risk-based, effectiveness-oriented AML/CFT framework that better targets illicit finance risk while preserving flexibility for community banks.

ICBA emphasizes that the final rule must recognize the operational realities of smaller, relationship-based institutions and avoid imposing expectations better suited to large, complex organizations.