On Nov. 29, the Senate Banking Committee held a hearing to discuss legislative reform in combating money laundering and other forms of illicit finance. Credit Union National Association (CUNA) wrote to Senate leadership to spotlight the difficulties credit unions face to comply with Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements.

CUNA supports efforts to track money laundering and terrorist financing but also believes it’s important to strike the balance between the costs to financial institutions, like credit unions, and the benefits to the federal government from the BSA, AML, and Office of Foreign Assets Control (OFAC) regulations. Credit unions would like to see changes that address redundancies, unnecessary burdens, and opportunities for efficiencies with the BSA/AML framework.

Specifically, CUNA recommends the following technical changes:

  • SAR and CTR Forms Should Be Combined
  • Reporting Thresholds and Deadline to File Should Be Increased to Reflect Today’s Environment
  • “Beneficial Owner” and Beneficiaries Requirements
  • Monetary Instrument Purchases
  • Zero Tolerance for Unintentional Non-Compliance Should Be Reconsidered