FinCEN and the Federal Reserve Board ("FRB")
(together, the "Agencies") proposed to significantly reduce the
dollar-value threshold at which the Bank Secrecy Act
("BSA") requires financial institutions to obtain, retain
and transmit information on certain fund transfers and
transmittals.
In a joint proposed rule, the Agencies proposed to reduce the
threshold under the "Recordkeeping Rule" (BSA Rules
1010.410(e) and
1020.410
(a)) and under the "Travel Rule" (BSA Rule
1010.410(f)) from $3,000 to $250 for funds transfers and
transmittals that begin or end outside the United States. The
Agencies stated that the reduction is intended to provide for the
"preservation of information that would benefit law
enforcement and national security investigations." FinCEN
stated that the reduction is appropriate, as it may supplement
potentially unidentified suspicious transactions for which
financial institutions may fail to submit suspicious activity
reports. The Agencies
