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The League submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) in response to their recent rulemaking to incorporate the changes of the Anti-Money Laundering Act of 2020 (AMLA) into their administrative rules.
The League’s comment letter focused on ensuring that the process is designed to avoid an increased burden on credit unions who are already strong partners in the effort to combat money laundering and the financing of terrorism.
The rule looks to implement a risk-based process for filing reports but doesn’t seem to contemplate that many credit unions use third-party vendors to assist in their OFAC matching and identity verification. The League asked FinCEN to provide clear guidance to reconcile what seems to be a disconnect from the work currently being done. In addition, the League cautioned FinCEN to adopt rules that make SARs and CTRs more actionable for law enforcement and avoid incentivizing the over-submission of reports for credit unions.
Later this month, the League will be weighing in on the same issue with NCUA, keeping the focus on how the rules should be integrated into their examination procedures. Any credit union with suggestions or input should reach out to Ellen Parent, League Director of Compliance, at eparent@mainecul.org.