FinCEN AML/CFT Priorities: The Eight Priorities Explained

In June 2021 the US Financial Crimes Enforcement Network (FinCEN) issued its first national AML and counter-terrorist financing priorities. They name the crime types that the US government considers the most significant threats to the financial system. This guide summarises the priorities document and the news release that accompanied it. It supports our understanding of how risk-based programs are meant to work and connects to our guides on the April 2026 proposed program rule, the bank AML program rule and the firm-wide risk assessment.

What the priorities are

The priorities were issued on 30 June 2021 under the Anti-Money Laundering Act of 2020. FinCEN lists eight, "in no particular order": corruption, cybercrime (including cybersecurity and virtual currency), foreign and domestic terrorist financing, fraud, transnational criminal organization activity, drug trafficking organization activity, human trafficking and human smuggling, and proliferation financing. The document says money laundering is not a separate priority because it is linked to all eight. FinCEN says it will update the priorities at least once every four years.

Highlights from each priority

• Corruption: citing a June 2021 national security study memorandum, the document says corruption may reduce global GDP by 2 to 5 percent.
• Cybercrime: it says North Korea-linked cyber actors likely stole hundreds of millions of dollars in convertible virtual currency since 2019, and that ransomware attacks increased dramatically in 2020 and 2021. Mixers and tumblers are named as layering tools.
• Terrorist financing: most groups still rely on banks, money services businesses and cash couriers, and domestic extremists are described as hard to detect because of their insular radicalisation.
• Fraud: the document says fraud is believed to generate the largest share of US illicit proceeds. It cites an estimate of about $100 billion a year for health care fraud and 32,000 business email compromise cases involving almost $9 billion in attempted theft, reported by FinCEN for 2019.
• Transnational criminal organizations: professional money laundering networks that charge a fee launder proceeds regardless of the predicate crime.
• Drug trafficking organizations: Asian, primarily Chinese, professional networks act as money brokers in trade-based money laundering.
• Human trafficking and smuggling: laundering methods include cash smuggling, shell companies, funnel accounts and trade-based money laundering.
• Proliferation financing: global correspondent banking is described as a principal vulnerability, because of its role in processing US dollar transactions.

What institutions were told to do

FinCEN's news release said that covered institutions were not required to make any immediate changes to their risk-based AML programs. It also said examinations for incorporating the priorities would not take place until implementing regulations had been promulgated, while suggesting that institutions may wish to start considering how they would incorporate them. The priorities document says FinCEN will issue regulations specifying how institutions incorporate the priorities into risk-based programs, and notes that not every priority will be relevant to every institution.

Suspicious activity reports and key terms

The priorities document reminds covered institutions of their existing obligations to identify and file suspicious activity reports on potential terrorist financing transactions. It also encourages the use of FinCEN's COVID-19 SAR key terms for fraud and cyber-related filings. In other words, the priorities sit on top of the SAR system, which gives FinCEN and law enforcement a way to connect reports to the themes the government is focused on. The document cites advisories dated between 2016 and 2021, including those on ransomware, convertible virtual currency, money mules and imposter scams, which show where the cybercrime priority gets its typologies.

Why the priorities still matter

Even where they do not create separate duties, the priorities show how FinCEN frames risk. Several link directly to other FinCEN publications, including advisories on ransomware, human trafficking, trade-based money laundering and correspondent banking. They also connect to the proposed program rule we have covered, where risk assessment is central. FinCEN's human trafficking advisory shows how one priority turns into specific red flags.

Using this in an AML role: our suggestions

These steps are our suggestions, not requirements in the priorities document.

• Map your customer base and products to each of the eight priorities in your risk assessment, and record which are not relevant and why.
• Link each priority to the FinCEN advisories and red flags your monitoring already uses.
• Note the date of the priorities you relied on, since FinCEN says it will update them at least every four years.

For structured learning, browse our CPD courses.

What we could not confirm

The priorities are from June 2021, and FinCEN may have updated or replaced them since, so check its website for the current version. We did not read the two separate statements that FinCEN issued on applicability, and the document does not describe examination expectations. The statistics come from the document and the agencies it cites, and we did not verify them independently. This post covers US rules only and is general information, not legal advice.