Anti-Money Laundering compliance programs
Anti-money laundering compliance in the Technology, AI and Competition sector is no longer a peripheral concern for payments-adjacent firms. The Financial Crimes Enforcement Network has expanded its interpretation of "financial institution" under 31 C.F.R. § 1010.100 in ways that pull certain technology platforms and digital asset infrastructure providers into mandatory AML program requirements, and the European Banking Authority has issued guidance pressing member-state supervisors to scrutinize crypto-adjacent tech firms with the same rigor applied to traditional payment processors. Compliance teams at technology companies are actively auditing whether their customer onboarding flows, transaction monitoring tools, and third-party data processors meet program adequacy standards before examination cycles begin.
Watch
- FinCEN's proposed rulemaking on digital asset intermediaries and AML program obligations
- EBA's 2024 AML/CFT supervisory convergence priorities for non-bank payment technology firms
- Whether your firm's AI-driven transaction screening tools satisfy Financial Crimes Enforcement Network's "reasonable procedures" standard
- Competition regulators cross-referencing AML compliance gaps during merger clearance reviews of fintech acquisitions
Recent material activity in Technology, AI & Competition
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NIST releases updated AI Risk Management Framework companion guide for critical infrastructure
NIST published AI RMF 1.1 companion guidance specifically addressing AI deployment in critical infrastructure sectors including energy, financial services, and healthcare. The guide introduces mandatory risk assessment c…
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