In a letter to the Financial Crimes Enforcement Network today, ABA expressed support for a proposal that would subject banks without a functional federal regulator to the same Bank Secrecy Act and anti-money laundering rules as federally regulated institutions.
This would include the establishment of an AML program consisting of policies and procedures, a designated compliance officer, employee training and an internal audit function. Non-federally regulated banks would also be required to establish a customer identification program and comply with FinCEN’s final beneficial ownership rule.
ABA recommended that FinCEN allow (at minimum) a two-year compliance period for affected institutions to make necessary changes to rules and processes.
