U.S. Treasury Undersecretary for Terrorism and Financial Intelligence ("TFI") Sigal Mandelker described TFI efforts to strengthen the financial crimes enforcement framework. She also encouraged cooperation between the public and private sectors to bolster anti-money laundering ("AML") efforts.

At the American Bankers Association and American Bar Association Financial Crimes Enforcement Conference, Ms. Mandelker shared several recent actions undertaken by the TFI in order to address national security threats. These include a new actions  prohibiting dealings with a Chinese bank accused of facilitating North Korean access to the U.S. financial system, and the targeting of illicit activity related to Iran, Venezuela and Russia. Ms. Mandelker identified sanctions, enforcement actions, financial advisories, and global and domestic collaborative initiatives as essential elements of TFI efforts. She pledged clear communication of expectations to the private sector, and encouraged the compliance community to be continually vigilant in helping to supplement the TFI's tools and authorities.

Ms. Mandelker highlighted the necessity of ensuring transparency and accountability through an effective AML framework. She said the TFI is reviewing the Bank Secrecy Act to identify and address areas in need of improvement. In addition, Ms. Mandelker said that the TFI is focused on facilitating partnerships between the public and private sectors. These partnerships, she asserted, can be important protective measures against vulnerabilities that allow illicit activity to pervade the financial system. Ms. Mandelker pointed to advisories as particularly useful tools for helping the private sector identify and report suspicious activity.

Ms. Mandelker reported that the TFI will continue to engage with financial institutions to promote more efficient information sharing among institutions, and between institutions and regulators. She touted the recently created FinCEN Exchange as an initiative that will help to accomplish this mission. Widespread voluntary participation will help to strengthen communication channels and improve the AML framework without imposing additional regulatory burdens, she said.

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