A proposed rule from the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) would reduce confusion for privately insured credit unions seeking clarification on their Bank Secrecy Act (BSA) requirements, CUNA believes. CUNA submitted a comment letter to FinCEN Monday on the agency’s proposed rule that affects about 125 privately insured credit unions.
Specifically, the proposed rule would prescribe minimum standards for anti-money laundering programs for “banks lacking a federal functional regulator” to ensure that all banks, regardless of whether they are subject to federal regulation and oversight, are required to establish and implement anti-money laundering programs.
“CUNA supports the proposed rule as issued. Over the years, CUNA has received questions from privately insured credit unions seeking clarification on their BSA requirements, including those addressed by the proposed rule,” the letter reads. “The proposed rule change should reduce confusion that has popped up from time to time regarding expectations and requirements of privately insured credit unions.”
The proposal would also extend customer identification program requirements and beneficial ownership requirements to those banks not already subject to these requirements.
CUNA asked FinCEN for a minimum of 6 months between the rule’s publication in the Federal Register and the effective date. This will allow these institutions to assess current operations to see if changes are necessary.
CUNA also asked FinCEN to consider whether it would be appropriate to expand the scope of the proposed rule to certain payment and acceptance services such as PayPal, Western Union and Apple Pay.