The National Consumer Law Center (“NCLC”) (on behalf of its low-income clients), National Community Reinvestment Coalition, and National Consumers League appreciates the opportunity to submit comments to the Financial Crimes Enforcement Center (“FinCEN”) regarding the modernization of the current Bank Secrecy Act, Anti-Money Laundering, & Counter-Financing of Terrorism (collectively, “AML”) regime. Specifically, we urge greater attention to fraud against consumers who are induced to send payments to scammers. Stronger protections for consumers who are defrauded is the best way to promote more innovative, risk-based approaches to preventing financial scams.