Impact of FRB and FinCEN proposed amendments to recordkeeping and travel rule regulations

The FRB and the FinCEN issued proposed new rules that would expand recordkeeping and travel rule regulations.

Edwige Sacco

Edwige Sacco

Principal, KPMG US

The Federal Reserve Board (FRB) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed new rules that would expand the applicability of recordkeeping and travel rule regulations, while potentially increasing collection requirements for financial institutions engaged in cross-border money transfers. The proposed changes are intended to improve national security by making it harder for criminals to stay below the radar of law enforcement and regulatory agencies.

Topics discussed include:

  • Motives driving the proposed amendments
  • How the new rules compare to current global standards—and what could result from inconsistent practices across jurisdictions
  • How the scope of the changes could impact domestic transactions, as well as the more obvious cross-border transactions
  • Possible impacts to training, technology infrastructure, screening processes, and policies in order to comply with the rule changes
  • Why compliance will be particularly challenging for virtual asset service providers and others that deal in cryptocurrency
  • Specific examples of the resulting cost and operational burdens on the private-sector--from the perspective of PayPal.

A panel deeply experienced in anti-money laundering laws and regulations, podcast participants include:

  • Joanne Li, Director of Global Financial Crime, PayPal
  • Caroline Brown, Partner, Crowell & Moring LLP
  • Carlton Greene, Partner, Crowell & Moring LLP
  • Edwige Sacco, Principal, KPMG