Proposal to Revise Recordkeeping and Travel Rule Requirements Poses Implementation Challenges for FIs and VASPs

November 5, 2020 - Policy Alerts

The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements, while potentially increasing information collection requirements for all financial institutions (FIs) engaged in any aspect of crossborder money transfers.

The proposed rules would further solidify the requirement that virtual asset service providers (VASPs) comply with the travel rule and with recordkeeping requirements related to funds transfers. On October 27, the FRB and FinCEN (“the agencies”) issued a Joint Notice of Proposed Rulemaking (NPRM) describing plans to lower, to $250 from $3,000, the threshold for the application of recordkeeping and information transmission requirements related to cross-border funds transfers/transmittals.

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