CBA Statement on Regulators BSA/AML Innovation Announcement

December 3, 2018
Nick Simpson


CBA Statement on Regulators BSA/AML Innovation Announcement


WASHINGTON – The Consumer Bankers Association today said the announcement made by the U.S. Department of Treasury’s Financial Crimes Enforcement Network and prudential regulators encouraging financial institutions to explore more innovative approaches to combat money laundering and illicit terrorist financing is an important first step in improving current Bank Security Act and anti-money laundering rules, regulations and guidelines.


“Giving banks the opportunity to innovate will help make our financial system more secure,” said CBA President and CEO Richard Hunt. “Criminals and terrorists are constantly evolving and using increasingly advanced methods to move money and finance their operations. It only makes sense for federal regulators to give financial institutions the ability to work toward staying a step ahead.


“We would like to thank FinCEN, the Fed, OCC, FDIC and NCUA for their efforts.”  


To more fully update the existing BSA/AML framework, CBA has recommended in a letter to Congress:


  • Amending reporting thresholds: CBA supports raising the reporting threshold for financial institutions from $5,000 to $10,000 for suspicious activity reports (SARs) and from $10,000 to $30,000 for currency transaction reports (CTRs).  The current thresholds, established decades ago, have not been adjusted for inflation or otherwise amended.


  • Requiring beneficial ownership information be verified at the time a legal entity is formed: Shell companies with anonymous ownership provide shelter for criminals and every effort should be made to prevent these entities from accessing the nation’s financial system.  CBA strongly encourages the Committee to consider measures that would require beneficial ownership information to be collected and verified by a government agency at the time a legal entity is formed and before corporate owners attempt to access the financial system at account opening.


  • Streamlining reporting requirements and encouraging technological innovation: It is CBA’s position that FinCEN, the banking agencies, and law enforcement should periodically conduct a formal review of the reporting requirements under the BSA and its implementing regulations to ensure the information reported by and collected from financial institutions has a high degree of usefulness to law enforcement.




 About the Consumer Bankers Association
The Consumer Bankers Association represents America’s leading retail banks. We promote policies to create a stronger industry and economy. Established in 1919, CBA’s corporate member institutions account for 1.7 million jobs in America, extend roughly $4 trillion in consumer loans and provide $275 billion in small business loans annually. Follow us on Twitter @consumerbankers.