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ABA: The American Bankers Association

Bank Secrecy Act / Anti-Money Laundering (BSA/AML) Reform

The Role of Banks in an Efficient and Effective Anti-Money Laundering Program

ABA Position

America’s Banks play a critical role in the fight against financial crime, money laundering, and terrorist financing. ABA has long supported these efforts by banks, with an emphasis on making the system more efficient and effective in providing information to law enforcement.

ABA supported Congressional efforts to adopt the Anti-Money Laundering Act of 2020 (AMLA), part of the National Defense Authorization Act, as we have supported Congressional efforts over the past decades to improve the system. AMLA is a good first step to reforming the system, and ABA looks forward to working closely with Treasury, FinCEN, and the prudential regulators as continued efforts are undertaken to streamline the system and make it more effective and efficient by:

  • Setting up the federal “beneficial ownership” registry to simplify the process for banks to identify the real people behind the legal entities they serve
  • Streamlining information sharing between banks, and between banks and law enforcement, to ensure that resources are being appropriately allocated to address current law enforcement priorities
  • Raising the Currency Transaction Report (CTR) threshold, which has not been adjusted since it was established in 1970, to reflect years of inflation and refocus resources on truly suspicious transactions
  • Adopting a seasoned customer exemption that would let banks exempt customers, within parameters established by Treasury, to eliminate unnecessary CTR filings, and
  • Focusing on the risk-based compliance approach to BSA/AML exams in order to make the most productive use of AML resources.

ABA will continue partnering with law-makers, federal banking regulators, law enforcement groups, and bankers to find common sense improvements to the current framework that will support law enforcement while minimizing unnecessary regulatory burdens.

ABA also actively supports regulatory initiatives designed to improve the BSA/AML system:

  • Interagency cooperation among the prudential regulators to identify steps that can streamline the process and eliminate inefficiencies, particularly steps to promote innovation.
  • FinCEN efforts to identify metrics that can quantify and measure success to ensure that resources are used wisely.
  • FinCEN efforts to evaluate the effectiveness of the BSA compliance regime to identify steps that can eliminate unnecessary reporting, facilitate information sharing between financial institutions and to-and-from law enforcement.
  • Efforts to identify and share law enforcement priorities with the financial sector to let banks make the most efficient and effective use of limited resources.
  • Ensuring that the risk-based approach to BSA compliance is reflected in the examination process, keeping the FFIEC BSA/AML examination manual updated, and providing interagency and regular training for BSA examiners.
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Heather Trew

SVP & Counsel (Bank Secrecy Act, Anti-Money Laundering, Sanctions)

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