Updating anti-money laundering and countering the financing of terrorism (AML/CFT) rules and regulations would relieve significant—and increasing—compliance burdens on credit unions, America’s Credit Unions wrote to the Financial Crimes Enforcement Network (FinCEN) Friday. The comments were sent in response to a FinCEN request for comment on Currency Transaction Report (CTR) filing.
“The current CTR threshold [of $10,000] simply does not serve the goals and original intent of the Bank Secrecy Act (BSA). Further, the balance between useful reporting and burden on credit unions is wildly disproportionate,” wrote America’s Credit Unions’ Luke Martone. “The current threshold should be increased to account for inflation and economic changes over the past several years. America’s Credit Unions urges FinCEN to use its existing authority to increase the threshold to $30,000.”
Martone added that the $10,000 threshold was established in 1972 upon enactment of the Bank Secrecy Act and would exceed $75,000 if adjusted for inflation as of February 2024.
“While the individual reports themselves do not take significant time to file, credit unions report that the ‘sheer volume’ of CTR reporting is a compounding burden on credit union resources and staff time,” Martone said. “Credit unions have reported that their CTR filings have increased by up to 40% year-over-year during the last five years.”
