On July 13, BPI submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) in response to the agency’s proposal to renew, without change, currently approved information collections requiring certain financial institutions to file Currency Transaction Reports (CTRs). BPI appreciates the agency’s efforts to further enhance its assessments of the burden imposed on financial instructions by these requirements but believes that renewing these requirements without change would forgo an important and constructive opportunity to improve the effectiveness and efficiency of the reporting framework.
BPI suggests that the agency should revise its burden assessment to include the full scope of resources invested in pre-filing reviews, identification, technology, training, testing and quality assurance. Additionally, CTR requirements should be streamlined and modernized to facilitate automated filings of currency transactions at a certain dollar threshold. Finally, a holistic review of the U.S. AML/CFT regime is needed to prioritize reporting of a high degree of usefulness to law enforcement.