BPI Statement for the Record on House Oversight Hearing of FinCEN and TFI

Washington, D.C. – The Bank Policy Institute submitted a statement for the record today to the U.S. House Financial Services Committee for its oversight of the Financial Crimes Enforcement Network and the Office of Terrorism and Financial Intelligence. The statement acknowledges the diligence of FinCEN staff but expresses disappointment that examinations for AML compliance have not changed in response to the requirements of the new law.

“Four years since the enactment of the Anti-Money Laundering Act, the AML/CFT examination process remains dysfunctional — focused more on process than substance, more on immaterial matters than material ones,” BPI states. “Many of these key provisions of the Act have not been implemented. Meanwhile, the federal banking agencies have ignored the spirit of the Act, as their examinations continue to produce the problems that the Act was designed to solve.” 

Important background:

  • BPI launched an empirical study in 2017 to determine the effectiveness of the United States AML/CFT regime based on data and feedback from banks, law enforcement and other stakeholders.
  • The study resulted in a 2018 report finding that while banks devote thousands of employees and billions of dollars to BSA/AML and sanctions compliance, those efforts are ill-suited to effectively combat illicit finance.
  • As a result of these findings, BPI collaborated with a diverse coalition of stakeholders, including FACT Coalition, law enforcement and national security experts, business associations and non-profit groups to support the passage of the Anti-Money Laundering Act of 2020 – the first major legislative reform to U.S. AML laws since the 1970s.
  • Among its many requirements, the Anti-Money Laundering Act called on the Treasury Department to fundamentally reform the AML/CFT regime to encourage innovation and promote the adoption of technology.
  • Many of the key provisions of the Act have yet to be implemented.

What does BPI recommend?

BPI is asking Congress to urge the Department of Treasury to seek public comment and advance the many reforms mandated in the Anti-Money Laundering Act. BPI specifically makes twelve recommendations that would enhance banks’ ability to combat illicit finance and effectively support law enforcement.

To access the full statement, please click here.


About Bank Policy Institute

The Bank Policy Institute (BPI) 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 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

Media Contact

Austin Anton
Bank Policy Institute

Media Inquiry

  • This field is for validation purposes and should be left unchanged.