Two separate – but closely coordinated – notices of proposed rulemaking (NPRMs) were published to amend the anti-money laundering and countering the financing of terrorism (AML/CFT) requirements for certain financial institutions. The Financial Crimes Enforcement Network (FinCEN) published a proposed rule emphasizing effectiveness and outcomes over technical compliance, along with a risk-based approach directing more attention and resources toward higher-risk customers and activities. The same …