The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and Senator John Kennedy, with support from several Republican co-sponsors.

For the first time in over five decades, the bill would modernize key components of the Bank Secrecy Act (“BSA”). Some key proposed changes include: (1) increasing the reporting thresholds, (2) instituting periodic inflation adjustments, and (3) requiring Treasury to update and rationalize reporting processes and related form.  Industry groups, including the American Bankers Association and leading credit unions and community banking associations, have expressed support.

This article summarizes the bill’s core provisions that may impact banks, credit unions, money services businesses, and businesses that engage in large cash transactions.

The Financial Crimes Enforcement Network (“FinCEN”) has recently taken two steps in furtherance of the Trump Administration’s deregulatory agenda.  In late September, FinCEN posted a notice to the Federal Register soliciting comments on a proposed “Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Compliance” to be completed by non-bank financial institutions (“NBFIs”).  On October 9, FinCEN published a series of frequently asked questions (“FAQs”) aimed at clarifying the requirements around filing suspicious activity reports (“SARs”).  Both actions point to an effort to ease compliance costs and align compliance efforts with law enforcement priorities.