Comments Due to NAFCU: FinCEN - Recordkeeping and Travel Rule
NAFCU would like to highlight the following:
- The NPRM would reduce the Recordkeeping and Travel rule threshold from $3,000 to $250 for funds transfers and transmittals of funds that begin or end outside the United States.
- In addition, the proposal would define the meaning of “money” in the Recordkeeping and Travel Rules to apply to domestic and cross-border transactions involving convertible virtual currency (CVC).
- The NPRM does not impose any new requirements to retain additional or new information under the Recordkeeping and Travel Rules, other than those resulting from the change to the applicable thresholds.
Comments due to NAFCU: November 24, 2020
Comments due to FinCEN: November 27, 2020
NAFCU will send comments on behalf of its members to the FinCEN by their deadline (November 24, 2020).