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CUNA Senior Federal Compliance Counsel Colleen Kelly, Senior Director of Advocacy Luke Martone, and credit unions from CUNA’s Examination and Supervision Subcommittee met with the U.S. Government Accountability Office (GAO) this week to discuss issues related to the Financial Crimes Enforcement Network’s (FinCEN) Currency Transaction Report (CTR) requirements.
The GAO’s review of the CTR process is required by the Anti-Money Laundering Act of 2020.
CUNA and credit union staff shared how FinCEN can make the reporting process easier for credit unions, helping the agency and credit unions achieve the mutual goal of combatting illicit finance.
CTR thresholds have not been updated since the enactment of the Bank Secrecy Act in 1972, and CUNA has consistently advocated for updates, since they are among the most time-consuming part of a compliance program.
CUNA supported legislation in the last Congress to raise CTR and Suspicious Activity Report thresholds, and has recommended numerous efficiencies FinCEN could take to ease the reporting burden on financial institutions.