CUNA to Senate Banking: BSA/AML Regulations Must be Tailored and Proportioned for Credit Unions

May 21, 2019


May 21, 2019 

Credit Union National Association (CUNA) today wrote to the Senate Banking Committee (SSBC) seeking reasonable protections, including those under the Bank Secrecy Act (BSA), aimed at reducing financial crimes. The letter was sent ahead of the committee’s hearing on combating illicit finance and takes a closer look at the Finance Crimes Enforcement Network’s (FinCEN) Customer Due Diligence (CDD) Rule and the associations concerns with BSA, anti-money laundering (AML), and Office of Foreign Assets Control (OFAC) regulations.  

The CDD Rule amends BSA regulations to improve financial transparency and prevent criminals and terrorists from misusing companies to disguise illicit activities and launder ill-gotten gains. CUNA supports these objectives and is further urging the SBC to encourage FinCEN to work with the credit union industry on compliance issues as they arise. 

“We support efforts to track money laundering and terrorist financing, but also believe it is important to strike the right balance between the costs to financial institutions, like credit unions, and the benefits to the federal government,” CUNA President/CEO Jim Nussle commented in the letter.  

CUNA supports wrote in support of changes that would address redundancies, unnecessary burdens, and opportunities for an efficient BSA/AML framework, including:  

  1. Minimizing the duplication of the same or similar information;  
  1. Providing additional flexibility based on the reporting institution type or level of transactions; 
  1. Curtailing the continually enhanced CDD requirements; 4. Increase the threshold requiring Currency Transaction Reports (CTRs);  
  1. Reducing and simplifying the reporting requirements of Suspicious Activity Reports (SARs) that have limited usefulness to law enforcement; and  
  1. Allowing for greater regulatory and examination consistency among regulators, including the National Credit Union Administration (NCUA) and state credit union regulators, in order to help with interpretations of BSA requirements and guidance and to minimize regulatory overlap. 

Regulatory expectations for credit unions, often with small and stretched staffs, continue to grow and CUNA maintains that this factor must be considered in agency examinations and when laws and requirements are enacted. 

Read the letter in full here 


About CUNA:        
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 115 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit  


Lauren Williams      
CUNA Communications