GBBC USA Response to FinCEN Request for Comment – Anti-Money Laundering and Countering the Financing of Terrorism Programs

GBBC USA has submitted our response to Financial Crimes Enforcement Network (FinCEN)’s Request for Comment on modernizing AML/CFT program requirements under the Bank Secrecy Act. The proposed rule seeks to reform financial institutions’ AML/CFT program obligations by focusing on effectiveness, risk-based resource allocation, and better outcomes for law enforcement and national security.

GBBC USA supports FinCEN’s effort to recenter AML/CFT programs on practical effectiveness rather than process-driven compliance. Our response recommends that program effectiveness be tied to demonstrable outcomes, including higher-value reporting, better prioritization of high-risk activity, reduced false positives, and improved use of data and technology.

Our response also supports a flexible, risk-based approach that allows financial institutions to allocate resources according to their actual risk profiles. For institutions with digital asset exposure, this may include integrating blockchain analytics, digital identity, structured data, Travel Rule infrastructure, privacy-preserving information sharing, and other modern compliance tools into existing AML/CFT program architecture.

GBBC USA further recommends clearer supervisory guardrails, practical distinctions between establishing and maintaining a program, proportionate documentation and approval requirements, and a 12-month effective date for genuinely new programmatic requirements.

We appreciate the opportunity to contribute and stands ready to support further engagement as FinCEN advances the modernization of the Bank Secrecy Act and a more effective, risk-based AML/CFT framework.

Read the full response here.