Gacki is, in some quarters, seen as the architect of the USA's current sanctions regime at The Office of Foreign Assets Control or OFAC where she has been Director and also Treasury Department’s Under Secretary for Terrorism and Financial Intelligence.

For almost 20 years, directors of FinCEN have been almost anonymous. Appointing Gacki changes that.

But there are questions: OFAC is a flagship division of the US Treasury whereas, all too often, even the media don't understand FinCEN or how to set out its name. If, as it indicated, Gacki will take her experience but not her title in Terrorism and Financial Intelligence, it looks as if she's heading for a backwater.

Or it is an indication that, at last, Treasury is going to take FinCEN seriously, to do the things that should have been done over decades.

This is not to case aspersions on the efforts of previous Directors: their problems have, mostly, been of Treasury's, not FinCEN's making.

Gacki is almost an OFAC lifer: before becoming Director of OFAC, she served in multiple senior leadership positions at OFAC, including Deputy Director, Associate Director for Compliance and Enforcement, and Assistant Director for Licensing. Prior to OFAC, Gacki served as a trial attorney in the Federal Programs Branch of the Civil Division of the U.S. Department of Justice (DOJ), where she litigated a range of matters implicating key Terrorism and Financial Intelligence legal authorities.

It's definitely a step up for OFAC which has struggled to find directors in recent years. Whether it's a step down for Gacki remains to be seen. It is improbable that she would take the position without an exit strategy that would see her career advancement unaffected, as has been the case for several of her predecessors.