Certain updates and changes would make it less burdensome for credit unions to comply with anti-money laundering/counter-financing of terrorism (AML/CFT) rules and regulations, America’s Credit Unions wrote to the Financial Crimes Enforcement Network (FinCEN) Tuesday.
The comments are in response to a notice of proposed rulemaking (NRPM) required by the AML Act of 2020. It requires financial institutions to establish, implement, and maintain AML/CFT programs that are effective, risk-based, and reasonably designed.
“Credit unions are generally doing much of what is contemplated in this NPRM, particularly with regard to current risk assessment practices. However, the proposed addition of provisions into the AML/CFT program, such as the AML/CFT priorities, will be time- and resource-consuming, particularly for smaller credit unions,” wrote America’s Credit Unions Regulatory Advocacy Senior Counsel Luke Martone.
“Given that many of the provisions of the NPRM are statutorily required by the AML Act, including the AML/CFT priorities, it is imperative that credit unions be afforded adequate time to implement the changes contemplated in this proposal,” he added.
America’s Credit Unions also continued its advocacy for updated AML/CFT thresholds. It called for FinCEN to increase the Currency Transaction Report filing threshold to $30,000 (up from the current $10,000) and to support an increase to the Suspicious Activity Report filing threshold to at least $10,000 (up from the current $5,000). The thresholds have not been updated since 1972.
NCUA and other regulators requested comment on a related proposal to align requirements for supervised institutions to the FinCEN proposal. Comments on the joint proposal are due Oct. 8.
