ABA Letter to Senate re: Illicit Cash Act

The American Bankers Association (ABA) appreciates the opportunity to comment on the draft legislation known as the Illicit Cash Act. ABA is the voice of the nation’s $17 trillion banking industry, which is composed of small, midsize, regional and large banks that together employ more than 2 million people, safeguard $13 trillion in deposits, and extend nearly $10 trillion in loans. For many years, ABA has worked diligently to help make the United States regime to combat money laundering and terrorist financing more effective and efficient. ABA has served as a member of the Treasury Department’s Bank Secrecy Act Advisory Group (BSAAG) since its founding and for nearly 30 years, in conjunction with the American Bar Association, has offered one of the largest anti-money laundering conferences in the United States.

ABA believes that the draft legislation is a step in the right direction to make our anti-money laundering/combating the financing of terrorism (AML/CFT) more efficient. ABA has long advocated steps that would improve communications and feedback from law enforcement, and the bill includes several steps that would do that. ABA also supports provisions in the draft that would adapt new technologies to combat money laundering and terrorism. And finally, the draft bill would include a registry for beneficial owners that would be far more comprehensive, effective, and efficient than relying on individual financial institutions to collect the information and have it available for law enforcement when needed.