The Wolfsberg Group appreciates the opportunity to comment on FBAs’ Notice of Proposed Rulemaking for the AML Program Rule. We strongly believe that a proposed rule that implements Congress’ intention for the AML Act has the potential to generate a paradigm shift to bring about more effective outcomes and better oversight of the financial system, thereby protecting people and communities from financial crime related threats. The best way to execute this vision is by allowing FIs to implement a flexible risk-based approach, such that resources are appropriately allocated to where risks are the greatest and where priorities have been identified. The Program Rule is the cornerstone of a new AML/CFT regime and there will need to be other changes necessary to realise its benefits – not least, revisions to the FFIEC Examination Manual, and the roll out of examiner training; we look forward to working closely with the FBAs on the next steps throughout this journey.