BA Recommends Regulators Reconsider Dramatically Lowering Compliance Thresholds for Travel and Recordkeeping Rules
On Friday, the Blockchain Association responded to the Financial Crimes Enforcement Network and the Federal Reserve’s notice of proposed rulemaking (NPRM) that would lower the Travel and Recordkeeping rules’ compliance thresholds to $250 for transactions involving non-U.S. jurisdictions. The Association urged the agencies to reconsider this NPRM, the adoption of which would place a substantial burden on regulated financial institutions — especially virtual asset service providers and smaller firms — while undermining individual users’ privacy.
In addition, the Association maintained that the agencies did not provide sufficient evidence that adopting the proposed changes would materially benefit anti-money laundering or combatting the financing of terrorism enforcement relative to the significant costs it would impose on the public. Therefore, the Association recommended that the agencies reissue this NPRM and consider proposing a threshold for compliance that conforms to international standards.