The Financial Crimes Enforcement Network (FinCEN) under the U.S. Department of the Treasury recently issued its first-ever set of priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy. Covered firms will be expected to incorporate the priorities into their AML/CFT programs following FinCEN’s issuance of related regulations. Simultaneously, FinCEN and the Board of Governors of the Federal Reserve System issued parallel statements on their expectations for how and when banks and covered non-bank financial institutions must incorporate those priorities into their AML compliance programs. This article analyzes the FinCEN priorities and the accompanying explanatory statements, with commentary on the implications of those priorities for private fund managers from Perkins Coie partner Jamie A. Schafer and Miller & Chevalier, Chartered member William P. Barry. See “FBI Sees Significant Risk That Private Funds Are Used for Money Laundering” (Sep. 24, 2020).