House to consider bill to modernize BSA/AML framework

October 21, 2019

The Corporate Transparency Act of 2019 (H.R. 2513) and an offered amendment would provide much needed updates to the Bank Secrecy Act/Anti-money Laundering framework, CUNA wrote to House leadership Monday. The House is expected to consider H.R. 2513 this week.

“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 to financial institutions, like credit unions, and the benefits to the federal government,” the letter reads. “As such, we support, H.R. 2513, which addresses the redundancies, unnecessary burdens, and opportunities for efficiencies within the BSA/AML statutory framework.”

The letter notes that the dollar amounts for reporting thresholds in the BSA/AML framework haven’t been updated since the law’s inception in 1970, and that today’s threshold of $10,000 for Currency Transaction Reports is the equivalent of $1,500 when the law was first passed.

“And yet, credit unions are required to report every cash transaction of $10,000 or more, even when the credit union knows that the transaction has no criminal implications,” the letter reads. “This is a clear example of the compliance burden far outweighing the value of the information to law enforcement.”

CUNA also supports an amendment offered by House Financial Services Chairwoman Maxine Waters (D-Calif.), which would add the text of the COUNTER Act (H.R. 2514) to H.R. 2513. This would require indexing the CTR threshold every five years for inflation, as well as further study of the impact of Suspicious Activity Repots.