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BOARD OF GOVERNORS

OF THE

FEDERAL RESERVE SYSTEM

WASHINGTON, D.C. 20551 

DIVISION OF SUPERVISION

AND REGULATION

SR 21-10

June 30, 2021 

TO THE OFFICER IN CHARGE OF SUPERVISION

 AT EACH FEDERAL RESERVE BANK

SUBJECT: Interagency Statement on the Issuance of the Anti-Money

Laundering/Countering the Financing of Terrorism National Priorities

Applicability: This guidance applies to all financial institutions supervised by the Federal 

Reserve that are subject to the Bank Secrecy Act.

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance

Corporation, the National Credit Union Administration, and the Office of the Comptroller of the 

Currency (collectively, the federal banking agencies), the State bank and credit union regulators,

1

and the U.S Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) are 

issuing the attached Interagency Statement on the Issuance of the Anti-Money 

Laundering/Countering the Financing of Terrorism National Priorities (AML/CFT Priorities). The 

intent of the Interagency Statement is to provide clarity for banks2 on the AML/CFT Priorities. 

The Anti-Money Laundering Act of 2020 (the “AML Act”), 3 requires the Secretary of the 

Treasury, in consultation with the Attorney General, Federal functional regulators, relevant State 

financial regulators, and relevant national security agencies, to establish and make public, 

priorities for AML/CFT policy. Accordingly, FinCEN published these first national AML/CFT 

Priorities today. 

Today’s publication of the AML/CFT Priorities does not create an immediate change to 

Bank Secrecy Act (BSA) requirements or supervisory expectations for banks. The AML Act 

requires that, within 180 days of the establishment of the AML/CFT Priorities, FinCEN (in 

1 As represented by the Federal Financial Institutions Examination Council State Liaison Committee.

2 The term “bank” used here is as defined in Bank Secrecy Act regulations at 31 C.F.R. § 1010.100(d) and includes

each agent, agency, branch, or office within the United States of banks, credit unions, savings associations, and 

foreign banks. 

3 The AML Act was enacted as Division F, §§ 6001-6511, of the William M. (Mac) Thornberry National Defense 

Authorization Act for Fiscal Year 2021, H.R. 6395, 116th Cong.(2021) (enacted)(enrolled bill available at 

https://www.govinfo.gov/content/pkg/BILLS-116hr6395enr/pdf/BILLS-116hr6395enr.pdf). 
 

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consultation with Federal functional regulators and relevant State financial regulators) shall, as 

appropriate, promulgate regulations regarding the AML/CFT Priorities. 

The Interagency Statement confirms that banks are not required to incorporate the 

AML/CFT Priorities into their risk-based BSA compliance programs until the effective date of the 

final revised regulations; nevertheless, they should start preparing for any new requirements when 

those final rules are published. In addition, examiners from the federal banking agencies and

State financial regulators will not examine banks for the incorporation of the AML/CFT Priorities 

into their risk-based BSA programs until the effective date of the final revised regulations.

Federal Reserve Banks are asked to distribute this letter to the supervised institutions in 

their districts and to appropriate supervisory staff. In addition, supervised organizations may send 

questions regarding the Interagency Statement via the Board’s public website.4

Michael Gibson

Director

Division of Supervision and Regulation

Attachment: 

• Interagency Statement on the Issuance of the Anti-Money Laundering/Countering the 

Financing of Terrorism National Priorities

4 See, http://www.federalreserve.gov/apps/contactus/feedback.aspx
1

Board of Governors of the Federal Reserve System

Federal Deposit Insurance Corporation

Financial Crimes Enforcement Network

National Credit Union Administration

Office of the Comptroller of the Currency

State Bank and Credit Union Regulators

Interagency Statement on the Issuance of the Anti-Money Laundering/

Countering the Financing of Terrorism National Priorities

June 30, 2021

The Anti-Money Laundering Act of 2020 (the “AML Act”)1 requires the Secretary of the 

Treasury, in consultation with the Attorney General, Federal functional regulators,2

 relevant 

State financial regulators, and relevant national security agencies, to establish and make 

public priorities for anti-money laundering and countering the financing of terrorism policy 

(AML/CFT Priorities).3

 Accordingly, the U.S. Department of the Treasury’s Financial Crimes 

Enforcement Network (FinCEN) published these first national AML/CFT Priorities today 

in consultation with the parties as set out in the AML Act. As a result of this publication, 

the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance 

Corporation, the National Credit Union Administration, and the Office of the Comptroller of 

the Currency (collectively, the “federal banking agencies” or “FBAs”), State bank and credit 

union regulators,4

 and FinCEN are issuing this statement to provide clarity for banks5 on 

these AML/CFT Priorities. 

Today’s publication of the AML/CFT Priorities does not create an immediate change to 

Bank Secrecy Act (BSA) requirements or supervisory expectations for banks. The AML Act 

requires that, within 180 days of the establishment of the AML/CFT Priorities, FinCEN (in 

consultation with Federal functional regulators and relevant State financial regulators) shall, 

as appropriate, promulgate regulations regarding the AML/CFT Priorities.6

 Although not 

required by the AML Act, the FBAs plan to revise their BSA regulations, as necessary, to 

address how the AML/CFT Priorities will be incorporated into banks’ BSA requirements. 

1. The AML Act was enacted as Division F, §§ 6001-6511, of the William M. (Mac) Thornberry National Defense 

Authorization Act for Fiscal Year 2021, H.R. 6395, 116th Cong. (2021) (enacted) (enrolled bill available at 

https://www.govinfo.gov/content/pkg/BILLS-116hr6395enr/pdf/BILLS-116hr6395enr.pdf).

2. 31 U.S.C. § 5318(h)(4)(A) (as amended by AML Act § 6101(b)(2)(C)) uses the term Federal functional regulator 

“as defined in section 509 of the Gramm-Leach-Bliley Act (15 U.S.C. 6809)).”

3. 31 U.S.C. § 5318(h)(4)(A) (as amended by AML Act § 6101(b)(2)(C)).

4. As represented by the Federal Financial Institutions Examination Council State Liaison Committee.

5. The term “bank” used here is as defined in Bank Secrecy Act regulations at 31 C.F.R. § 1010.100(d) and 

includes each agent, agency, branch, or office within the United States of banks, credit unions, savings 

associations, and foreign banks.

6. 31 U.S.C. § 5318(h)(4)(D) (as amended by AML Act § 6101(b)(2)(C)).
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Banks are not required to incorporate the AML/CFT Priorities into their risk-based BSA 

compliance programs until the effective date of the final revised regulations. Nevertheless, 

in preparation for any new requirements when those final rules are published, banks may 

wish to start considering how they will incorporate the AML/CFT Priorities into their riskbased BSA compliance programs, such as by assessing the potential related risks associated 

with the products and services they offer, the customers they serve, and the geographic areas 

in which they operate.

Finally, the AML Act requires that the review by a bank of the AML/CFT Priorities and 

the incorporation of those priorities, as appropriate, into its risk-based BSA compliance 

program, be included as a measure on which a bank is supervised and examined.7

 This 

interagency statement confirms that State bank and credit union regulator and FBA 

examiners will not examine banks for the incorporation of the AML/CFT Priorities into their 

risk-based BSA programs until the effective date of final revised regulations. 

The FBAs, State bank and credit union regulators, and FinCEN recognize the need to 

provide revised regulations and timely guidance to assist banks in complying with the BSA. 

In addition, the FBAs and State bank and credit union regulators are committed to working 

with FinCEN to develop any necessary corresponding guidance and examination procedures 

for examiners.

7. 31 U.S.C. § 5318(h)(4)(E) (as amended by AML Act § 6101(b)(2)(C)).