In my May 2006 column, I wrote in part about the possibility of the U.S. Treasury Department requiring that banks report their cross-border funds transfers.1 Under the Intelligence Reform and Terrorism Prevention Act of 2004 (IRTPA, Pub. L. 108-458)(2004)), the Secretary of the Treasury was required to issue regulations requiring reporting of cross-border funds transfers if he determined such reporting was “reasonably necessary” in his efforts against money laundering and terrorism. Four years later, on Sept. 30, 2010, the Secretary issued proposed regulations to require reporting of cross-border funds transfers by banks and money transmitters to the Financial Crimes Enforcement Network (FinCEN), the Treasury Department’s anti-money laundering agency.2
These regulations likely will impact many U.S. offices of non-U.S. banks, particularly the larger offices. The comment period ends Dec. 29, 2010, and affected institutions should strongly consider sending a comment regarding the impact of the proposed rule on its operations. This month’s column will discuss the details of the proposed rule.
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