FinCEN intends to issue a Notice of Proposed Rulemaking (NPRM) following the implementation of Section 6305 of the AML Act. This section requires FinCEN to conduct an assessment on whether to issue no-action letters in response to specific conduct requests from third parties, and propose rulemaking if appropriate. The assessment concluded that FinCEN should issue no-action letters, subject to sufficient resources, and proposed rulemaking to follow the issuance of the report. FinCEN issued an Advance Notice of Proposal Rulemaking (ANPRM) on June 6, 2022, with a 60 day comment period closing on August 5, 2022. The ANPRM solicited public comment on questions pertinent to the implementation of a no-action letter process at FinCEN.  Given that the addition of a no-action letter process at FinCEN may impact or overlap with other forms of regulatory guidance and relief that FinCEN already offers, including exceptive or exemptive relief and administrative rulings, the ANPRM also sought public input on whether this process should be implemented and, if so, how a no-action letter process should interact with these other tools.  FinCEN has reviewed the comments submitted in response to the ANPRM and is considering the structure and timing of the issuance of the NPRM.