2022 National Strategy for Combating Terrorist and Other Illicit Financing

May 2022

The priorities and supporting actions of the 2022 Strategy are intended to address “significant” illicit finance threats and vulnerabilities. Notably, they are very broad in scope covering issues/areas raised in FinCEN’s AML/CFT National Priorities, Treasury’s 2022 National Risk Assessments, and multiple executive orders related to corruption, cybersecurity, and digital assets. The unprecedented levels of economic and financial sanctions activity associated with the Russia-Ukraine war have served to punctuate AML/CFT risks. Financial institutions should look to the 2022 Strategy as a guide to assessing their illicit finance exposure as well as to the areas of regulatory focus over the next few years. In the near term, financial companies should expect both new rulemakings and increased regulatory attention on matters involving beneficial ownership, customer due diligence, SAR filings, anti-corruption compliance programs, cybercrime, and virtual assets (crypto and digital currencies).