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The Financial Crimes Enforcement Network (FinCEN) today published a proposed rule to amend the Bank Secrecy Act's (BSA) recordkeeping and travel rule regulations. The amendments to the recordkeeping rule are proposed in coordination with the Federal Reserve Board.

Under the current recordkeeping and travel rule regulations, financial institutions must collect, retain, and transmit certain information related to funds transfers and transmittals of funds over $3,000. The proposed rule would lower the applicable threshold to $250 for international transactions, which could require credit unions to collect and report more information than they currently do. The threshold for domestic transactions would remain unchanged at $3,000.

The proposal also includes a clarification on the definition of "money" to ensure that the rules apply to domestic and cross-border transactions involving convertible virtual currency.

Comments on the proposal are due to the agencies in 30 days. NAFCU will continue to analyze the proposal and share how credit unions could be impacted by the adjusted international transaction threshold.