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FinCEN CDD Proposal Update; Virtual Currencies Guidance

The U.S. Treasury Financial Crimes Enforcement Network (FinCEN) will likely issue a proposed rule on customer due diligence (CDD) in the “coming weeks,” based on recent comments by senior U.S. Treasury officials.  Missouri Credit Union Association (MCUA) continues to advocate for more efficient Bank Secrecy Act rules that are risk-based, and for reduced regulatory burdens on credit unions that have limited compliance resources. Last year, FinCEN issued an advance notice of proposed rulemaking on CDD, and we noted in our comment letter significant concerns with increased regulatory burdens and costs, especially on the potential expansion of the “beneficial ownership” requirements. 

On a separate issue, FinCEN recently issued guidance on virtual currencies. The guidance is in response to questions raised by financial institutions, law enforcement, and regulators on the regulatory treatment of virtual currencies, such as Bitcoin and other types of online “credits.”