The Clearing House (TCH) and FSR filed a letter with the Treasury Department on its Review of Regulations, which was issued under Executive Orders 13771 and 13777 to facilitate public review and recommendations regarding Treasury regulations and guidance, including those promulgated by FinCEN and OFAC that could be “eliminated, modified, or streamlined in order to reduce burdens.” The letter recommended that: (i) Treasury/TFI/FinCEN, as the agency entrusted with authority under the BSA, should communicate clear expectations to industry and other stakeholders, through regulations and guidance with respect to customer due diligence and related obligations; (ii) Treasury/TFI/FinCEN should reform the BSA/AML reporting regime and expand information sharing authorities to enhance law enforcement’s ability to apprehend criminals and counter terrorism in the 21st century; (iii) Treasury/TFI/FinCEN, in consultation with the federal banking agencies, should address the drivers of de-risking to prevent further damage to critical U.S. policy interests; and (iv) Treasury/TFI/OFAC should increase the efficiency and effectiveness of sanctions compliance, and further recognize a risk-based approach to compliance. More granular proposals were provided on each recommendation.
You Might Also Be Interested In...
AML, Bank Secrecy Act and Sanctions BPI’s Heather Hogsett Testifies Before House Subcommittee on Cybersecurity, CISA’s Contributions
AML, Bank Secrecy Act and Sanctions FinCEN Must Preserve Beneficial Ownership Data Usefulness, Discourage Inappropriate Reporting Omissions
AML, Bank Secrecy Act and Sanctions BPI Responds to FinCEN Request for Comments Regarding Beneficial Ownership Information Reports
AML, Bank Secrecy Act and Sanctions Russian Oligarchs Hide Money in U.S. Only Reliable Data Can Stop Them.
AML, Bank Secrecy Act and Sanctions BPI Comments on FinCEN Proposed Rulemaking on Access to and Safeguards for Beneficial Ownership Information
AML, Bank Secrecy Act and Sanctions Business-Ownership Registry Access Rules Should Ensure Banks Can Focus on Threats
AML, Bank Secrecy Act and Sanctions BPI and ABA Respond to FinCEN Advanced Notice of Proposed Rulemaking on Establishing a No Action Letter Process
More Posts by This Author
Bank Capital and Stress Testing U.S. Bank Capital Levels: Aligning With or Exceeding Midpoint Estimates of Optimal
Central Bank Digital Currency BPI’s Paige Pidano Paridon Testifies on CBDC Before House Subcommittee
Bank Activities and Structure BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Digital Assets, Financial Technology and Inclusion
Bank Activities and Structure BPI Statement Before the U.S. House Financial Services Committee’s Subcommittee on Financial Institutions and Monetary Policy
Basel Finalization BPI’s Greg Baer Testifies on Basel Endgame Before House Financial Services Subcommittee