Rob Rowe

September 30, 2022

This rule will strengthen the integrity of the U.S. financial system by making it harder for illicit actors to use shell companies to launder their money or hide assets.

June 06, 2022

FinCEN has issued an ANPRM asking for comment on the process by which a no-action letter process could work.

April 13, 2022

The change will let the OCC issue exemptions from SAR requirements on request from a financial institution.

March 29, 2022

ABA's response to the Venezuelan Embassy's letter re: Customer Identification Program.

March 28, 2022

We urge FinCEN to work with financial institutions prior to issuing a final rule in order to create a pilot program that will minimize the burdens and encourage participation.

March 01, 2022

Over the last several days, the United States has imposed a series of sanctions against Russia as a result of the Russian invasion of Ukraine. In an unprecedented show of unity, these sanctions have been closely coordinated with the European Union, the United Kingdom, and other U.S. allies. ABA will keep the staff analysis updated as developments occur.

February 14, 2022

ABA appreciates the opportunity to provide our comments as FinCEN looks to streamline and modernize the AML/CFT regime. Clearly, this will be an ongoing process that will evolve over time. Much of it will be accomplished as FinCEN implements the provisions of AMLA, and ABA looks forward to engaging with the agency on this work.

February 07, 2022

FinCEN is seeking comment on a proposed pilot program, subject to conditions set by FinCEN, that would allow financial institutions share SARs and information related to SARs with the institution's foreign branches, subsidiaries, and affiliates. The proposal is required by Section 6212(a) of the Anti-Money Laundering Act of 2020 (AMLA), a step recommended by ABA to streamline AML/CFT efforts and to facilitate enterprise-wide risk management (ERM) programs.

February 07, 2022

ABA has long supported the establishment of a beneficial ownership registry. However, since this is only the first of a three-part regulatory scheme to implement the beneficial ownership registry, several banks have pointed out that until the access regulation has been implemented and the CDD rule has been updated, it will be difficult to assess how these reporting requirements fit with bank responsibilities. Therefore, it is difficult, if not impossible, to determine whether this proposal meets the Congressional expectation for FinCEN to take steps to eliminate duplicative requirements and to reduce burden.

December 21, 2021

FinCEN is undertaking a review of its regulations and guidance to find ways to streamline, modernize, and update the current anti-money laundering and countering the financing of terrorism regime.

December 21, 2021

The Corporate Transparency Act, part of the Anti-Money Laundering Act of 2020, requires FinCEN to create a registry of the beneficial owners of many of the legal entities that have been established under state law in the United States. This proposal is the first in a series of three regulations designed to establish that registry.

December 03, 2021

In its ongoing efforts to update the FFIEC BSA/AML Examination Manual, the Federal Financial Institutions Examination Council (FFIEC) has added one new section and updated three other sections of the Manual.

July 12, 2021

On June 30, 2021, FinCEN issued the first government-wide policy priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT), as required by the Anti-Money Laundering Act of 2020.

May 05, 2021

ABA has long supported efforts to modernize the current anti-money laundering/countering the financing of terrorism (AML/CFT) regime, and we encouraged Congress to enact legislation establishing the beneficial ownership registry. Throughout, ABA has sought to make the BSA regime more risk focused, effective, and efficient.

April 16, 2021

ABA summary and guidance on the agencies' request for information on the extent to which the Model Risk Management Guidance supports compliance with BSA/AML requirements.

April 02, 2021

ABA summary of FinCEN's ANPRM on Beneficial Ownership Information.

February 22, 2021

ABA supports the concept of a special exemption for SAR filings to support innovative practices, but recommends that the agencies coordinate and file a single rule instead of three separate regulations.

January 25, 2021

The FDIC, the Federal Reserve, and the OCC have each published separate proposals to allow the agencies to authorize special exemptions from Suspicious Activity Report filing. The goal is to help encourage banks to take advantage of innovative solutions for monitoring and filing suspicious activity. A separate proposal, not covered in this analysis, was also published by the NCUA.

December 15, 2020

ABA summary of the Anti-Money Laundering Act Of 2020 Included in the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021.

November 27, 2020

The American Bankers Association (ABA) appreciates the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve (FRB) and the Financial Crimes Enforcement Network (FinCEN) (collectively, the Agencies) to lower the threshold for collecting and transmitting information associated with international funds transfers.