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John Zasada, Compliance Consulting Director, Financial Institutions Group

On October 23, 2020, the Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board announced a proposed rule amending the Bank Secrecy Act (BSA) recordkeeping and travel rule regulations. Currently, financial institutions must collect, retain and transmit certain information related to fund transfers over $3,000. The proposed rule would reduce this threshold from $3,000 to $250 for fund transfers that begin or end outside the United States. FinCEN is proposing to reduce from $3,000 to $250 the threshold in the rule requiring financial institutions to transmit to other financial institutions in the payment chain information on fund transfers and transmittals of funds that begin or end outside the United States. The agencies are also proposing to clarify the meaning of “money” as used in these rules so that the rules apply to domestic and cross-border transactions involving convertible virtual currency and cryptocurrency that either has an equivalent value as currency or acts as a substitute for currency. Comments on the proposed rule must be submitted on or before Nov. 27, 2020.

For more information on how this may impact your bank or credit union, contact a regulatory compliance specialist at Doeren Mayhew today.