While we are dismantling old systems and introducing new ones, the vulnerable among us may not always be able to keep up. They run a risk of becoming disenfranchised – a risk of being left out in the cold.
These initiatives are meant to respond to or anticipate questions that arise regarding anti-money laundering requirements. The Federal Reserve is keenly aware of the resources that anti-money laundering and counter-terrorist financing requirements demand of financial institutions and believes that it is our duty to assist them in meeting their obligations.