Testimony of Pete Selenke On Behalf of the ABA

Chairman Luetkemeyer, Ranking Member Beatty, and members of the subcommittee, thank you for the opportunity to testify today regarding "Potential Consequences of FinCEN’s Beneficial Ownership Rulemaking." My name is Pete Selenke, and I serve as Vice President and Anti-Money Laundering/Bank Secrecy Act Officer for The Central Trust Bank, a privately held $19 billion bank headquartered in Jefferson City, Missouri. As a banker with more than 32 years' experience in Bank Secrecy Act (BSA) compliance, I am personally and deeply committed to protecting the U.S. financial system, our bank and our bank customers from threats posed by badactors, and I have seen firsthand the successes and challenges of operationalizing BSA regulations. In fact, Central Bank has received two year-end awards from Treasury's Financial Crimes Enforcement Network (FinCEN) in recognition of our work assisting law enforcement in the past five years.

Today, I am pleased to speak on behalf of Central Bank and our 3,000 employees, as well as the American Bankers Association (ABA). The American Bankers Association is the voice of the nation’s $23.6 trillion banking industry, which is composed of small, regional, and large banks that together employ more than 2 million people, safeguard $19.4 trillion in deposits, and extend $12 trillion in loans.

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