Last September, the Financial Crimes Enforcement Network (FinCEN) requested comments on a proposed regulation in an advanced notice of proposed rulemaking (ANPRM) that would—for the first time—create efficacy standards for anti-money laundering (AML) programs. U.S. regulators have long developed and reinforced the importance of...

As the regulatory landscape shifts and turns in response to macroeconomic forces, technological innovation and geopolitical pressures, regulatory agencies amend existing rules and create new rules in an effort to ensure a level playing field for all. Outcomes are never guaranteed and those who follow...