Rob Rowe

November 20, 2020

The American Bankers Association appreciates the opportunity comment on questions raised by FinCEN about the costs and burdens financial institutions face when opening and maintaining foreign correspondent and private banking accounts.

November 16, 2020

The American Bankers Association appreciates the opportunity to comment on the advanced notice of proposed rulemaking considering regulatory changes to emphasize that AML programs must be "effective and reasonably designed." The goals set forth in the ANPRM are goals that ABA has supported for many years.

October 29, 2020

The Financial Crimes Enforcement Network has proposed renewing without change the information collected for foreign correspondent and private banking accounts. The proposal was published in the Federal Register on September 29 and comments are due November 30.

October 26, 2020

The Financial Crimes Enforcement Network and the Federal Reserve Board on October 23 proposed lowering the threshold for the records that banks and other financial institutions must collect and maintain for wire transfers that originate or end outside the United States.

September 18, 2020

In the September 17 Federal Register, FinCEN published an advanced notice of proposed rulemaking to address the effectiveness of anti-money laundering programs. The agency is considering possible regulatory changes to emphasize that AML programs must be "effective and reasonably designed."

August 21, 2020

ABA expressed support for the Consumer Financial Protection Bureau's proposed advisory opinion program, which would allow entities seeking to comply with existing regulations to request an advisory opinion from the bureau to address areas of uncertainty.

July 27, 2020

ABA's letter to FinCEN on its Request for Comments on the Suspicious Activity Report Renewal.

July 25, 2020

Comparison Chart of the House Version (Corporate Transparency Act/COUNTER Act) and Amendment Introduced (not adopted) in the Senate (the Anti-Money Laundering Act of 2020).

July 13, 2020

The American Bankers Association (ABA) appreciates the opportunity to comment on the Currency Transaction Report (CTR) proposal that the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register on May 14.

June 22, 2020

ABA summary on the Consumer Financial Protection Bureau's Advisory Opinions Proposal & Pilot.

June 22, 2020

ABA summary of DOJ's evaluation of corporate compliance programs.

June 02, 2020

ABA Staff Analysis on the Suspicious Activity Report Burden, comments due July 27, 2020.

May 29, 2020

ABA staff analysis on FinCEN's CTR form burden analysis. Comments due July 13, 2020.

April 20, 2020

ABA summary and guidance on the April 2020 updates to the Bank Secrecy Act/Anti-Money Laundering Examination Manual.

April 06, 2020

ABA staff analysis on FinCEN's guidance for banks coping with COVID-19.

March 17, 2020

Letter to Ken Blanco re: Currency Transaction Reports on Sole Proprietors and Legal Entities

January 21, 2020

The American Bankers Association (ABA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (Bureau) proposal to make two key changes to Regulation E, the rule that implements the Electronic Fund Transfer Act, particularly the subchapter on remittances.

October 15, 2019

ABA chart of BSA/AML reform legislation.

October 07, 2019

ABA summary and guidance on the Illicit Cash Act, designed to update the Bank Secrecy Act.

June 28, 2019