BSA/AML Modernization
Position Summary
Maintaining the financial system’s integrity is paramount. Nevertheless, the current BSA/AML framework is ineffective and inefficient. In the 2025 CSBS Annual Survey of Community Banks, bankers say BSA/AML represents 25% of their total compliance burden, and yet, less than 6% of Suspicious Activity and Currency Transaction Reports are utilized by law enforcement. Congress, Treasury, FinCEN, and state and federal financial services regulators must work together to reimagine the BSA/AML framework, tailor it to risk, and enable the use of modern technology to alleviate burden and strengthen national security.

BSA/AML Modernization News

Comment Letter

CSBS Comments on FinCEN Taxpayer ID Number Collection Requirement

Download the Full Comment Letter [PDF] Financial Crimes Enforcement Network Policy Division P.O. Box 39 Vienna, VA 22183 FINCEN-2024-0009 Re: Request for Information and Comment on Customer Identification Program Rule Taxpayer Identification Number Collection Requirement Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”) 1 provides the following comments on the notice and request for information (“RFI”) issued
May 28, 2024
Comment Letter

Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities

Download the Comment Letter Financial Crimes Enforcement Network Policy Division P.O. Box 39 Vienna, VA 22183 FINCEN‐2021‐0005 RIN 1506‐AB49/AB59 Re: Notice of Proposed Rulemaking ‐ Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”) 1 appreciates the opportunity to comment on the Notice of Proposed
February 14, 2023
Comment Letter

FinCEN No-Action Letter Process

Financial Crimes Enforcement Network Enforcement and Compliance Division P.O. Box 39 Vienna, VA 22183 FINCEN-2022-0007 RIN 1506-AB55 Re: Advance Notice of Proposed Rulemaking – No-Action Letter Process Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”)1 appreciates the opportunity to provide input on the Advance Notice of Proposed Rulemaking (“ANPR”) issued by the Financial Crimes Enforcement Network (“FinCEN”)
August 5, 2022
Comment Letter

Anti-Money Laundering Act of 2020

Read the full letter [PDF] The Honorable James Inhofe Chairman, Committee on Armed Services United States Senate Washington, DC 20510 The Honorable Jack Reed Ranking Member, Committee on Armed Services United States Senate Washington, DC 20510 Dear Chairman Inhofe and Ranking Member Reed, On behalf of the Conference of State Bank Supervisors (CSBS) 1, I am writing to express our
July 1, 2020

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