Credit unions support efforts to track money laundering and terrorist financing, but also believe it is important to strike the right balance between the compliance costs and benefits to the federal government, CUNA wrote to Senate Banking Committee leadership Wednesday before a hearing in which it will discuss draft legislation.
“We are encouraged by draft legislation the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings (ILLICIT CASH) Act This draft bill addresses the redundancies, unnecessary burdens, and opportunities for efficiencies within the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) statutory framework,” the letter reads.
CUNA appreciates several areas addressed in the draft legislation, including:
The letter also notes concern with at least one provision in the bill that CUNA believes could cause examination issues for some small credit unions.
“In Title III, we support the objective of the provision regarding transaction monitoring software intended to improve the risk-based system of tracking individual transactions,” the letter reads. “However, regardless of the Rule of Construction, it has been our experience that some examiners will expect the credit unions to comply with such ‘recommendations.’ We are concerned that ‘approved’ transactions monitoring software could cause a significant financial burden.”