WASHINGTON—CUNA is expressing support for the Financial Crimes Enforcement Network’s (FinCEN) Advance Notice of Proposed Rulemaking on anti-money laundering (AML) regulations for real estate transactions, but has also urged FinCEN not to place any unnecessary burdens on credit unions.
“[I]t is critically important that FinCEN strike the right balance between the imposition of compliance costs on leanly staffed, community-oriented credit unions and the benefits that AML programs can provide to law enforcement,” CUNA stated in a letter to FinCEN. “As FinCEN seeks to identify the proper scope for its rule, it should ensure that it does not impose duplicative or conflicting requirements.
Additional Request
“Further, it must ensure it does not task credit unions or credit union service organizations (CUSOs) with responsibility for the compliance of third-party entities,” the letter adds.
CUNA also called on FinCEN not to establish reporting requirements for credit unions regarding transactions in which they are not involved.
“FinCEN must not treat the smaller, community based financial institutions as a “clearinghouse” for all transactions to identify potential money laundering or terrorist financing activities,” the letter reads. “Doing so will have a direct, negative affect on smaller, community-based financial institutions.”
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