CBA Submits BSA/AML Improvement Recommendations


CBA Submits BSA/AML Improvement Recommendations


WASHINGTON – The Consumer Bankers Association today provided recommendations on improving Bank Secrecy Act and related anti-money laundering laws and regulations to the Senate Banking Committee in advance of a hearing on combatting money laundering and other forms of illicit finance. The letter was sent to Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Sherrod Brown (D-Ohio). CBA’s letter is available here.


CBA President and CEO Richard Hunt wrote, “CBA’s members promote national security interests and deter financial crimes by committing significant resources towards compliance with the Bank Secrecy Act (BSA), the USA PATRIOT Act, and related anti-money laundering (AML) laws and regulations.  Our members believe the current BSA/AML framework must be modernized to produce more useful information for law enforcement, alleviate compliance burdens on limited resources, and ensure BSA/AML serves as an effective tool in preventing criminals from accessing the financial system.”


To improve the existing BSA/AML framework, CBA recommended:


  • 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 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.