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As of April 1, 2020, there are 4994 open recommendations, of which 380 are priority recommendations. Recommendations remain open until they are designated as Closed-implemented or Closed-not implemented.
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Recommendation: The Director of FinCEN should jointly conduct a retrospective review of BSA/AML regulations and their implementation for banks with Federal Deposit Insurance Corporation (FDIC), the Federal Reserve, and Office of the Comptroller of the Currency (OCC). This review should focus on how banks' regulatory concerns may be influencing their willingness to provide services. In conducting the review, the FDIC, the Federal Reserve, OCC, and FinCEN should take steps, as appropriate, to revise the BSA regulations or the way they are being implemented to help ensure that BSA/AML regulatory objectives are being met in the most effective and least burdensome way. (Recommendation 1)
Agency: Department of the Treasury: Financial Crimes Enforcement Network Status: Open Priority recommendation
Comments: FinCEN did not indicate whether it agreed or disagreed with our recommendation. In April 2018, FinCEN agreed that the retrospective review would be beneficial and said it had been proactively working with stakeholders to review the effectiveness of the BSA regulatory and supervisory framework. FinCEN expects to complete its retrospective review by late March 2019.