Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

FINANCIAL SERVICES ISSUES TO WATCH: BSA/AML REFORM (1) Rising compliance costs and complexity

Role of private sector in policing financial system

Improving the feedback loop

Beneficial ownership information

FinCEN’s current and future capabilities

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FINANCIAL SERVICES ISSUES TO WATCH: BSA/AML REFORM (2)

H.R. 2514 COUNTER Act

H.R. 2513 Corporate Transparency Act

Unanimously approved by the House Financial Services Committee on May 9 • Strengthening FinCEN • Coordination and information sharing • Shared compliance resources • Study on de-risking • Encourage innovation in compliance • Index CTR threshold

Mark-up postponed • Aimed at combating illicit financial activity through anonymous shell companies • Requires disclosure to FinCEN of beneficial ownership information at the time of incorporation

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