February 14, 2022

NAFCU offers FinCEN recommendations on recordkeeping, reporting regulations

RegulationNAFCU’s Kaley Schafer wrote to the Financial Crimes Enforcement Network (FinCEN) Friday in response to a request for information (RFI) regarding the review of Bank Secrecy Act (BSA) regulations and guidance. Of note, the RFI specifically focused on current recordkeeping and reporting requirements and supports the mission outlined in the Anti-Money Laundering (AML) Act of 2020 that requires FinCEN to conduct a formal review of all BSA regulations.

In the letter, Schafer, NAFCU’s senior regulatory affairs counsel, called on FinCEN to provide additional guidance related to digital assets, government fraud, and cyber-enabled crime. In addition, she reiterated NAFCU's call to modernize and streamline the current suspicious activity reports (SARs) and currency transaction reports (CRTs) by increasing the reporting thresholds and removing any redundant or obsolete provisions.

Schafer also urged FinCEN to explore opportunities to provide feedback to credit unions regarding filed SARs or CRTs.

For more information on the RFI, NAFCU previously sent members a Regulatory Alert breaking down what credit unions need to know. NAFCU is supportive of BSA/AML reform efforts and will continue to update credit unions as FinCEN conducts its review of BSA regulations. Read Schafer's full letter.