To Whom It May Concern:
The Bank Policy Institute [1] appreciates the Financial Crimes Enforcement Network’s continued efforts to implement the Corporate Transparency Act (the “CTA”),[2] which was enacted as part of the Anti-Money Laundering Act of 2020 (the “AML Act”),[3] as well as the opportunity to respond to the proposed report that will be used to collect beneficial ownership information, as required by the Beneficial Ownership Reporting Requirements final rule that was published on September 30, 2022 (the “BO Reporting Rule”).[4] BPI has been and remains a strong supporter of ending the use of anonymous shell companies and continuing ongoing efforts to modernize the U.S. anti-money laundering/countering the financing of terrorism regime. BPI agrees, as recognized by Congress in the CTA, that uniform beneficial ownership information reporting requirements are important to more effectively combat illicit finance and to further the purpose of the AML Act and the Bank Secrecy Act more generally.
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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost two million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
[2] Pub. L. No. 116-283, Div. F, Tit. LXIV, 134 Stat. 4604 (2021).
[3]Pub. L. No. 116-283, Div. F, 134 Stat. 4547 (2021).
[4] 87 Federal Register 59498 (Sept. 30, 2022).
