,i  #aaeth ,,congress  #b;d ,session    
,h4 ,r4 #fjfh  ,,in ,,the ,,house ,,of  
,,representatives  ,june #ab1 #bjah,mr4 
,pearce 7for himself and ,mr4           
,luetkemeyer7 introduced the following  
bill2 which was referred to the         
,committee on ,financial ,services  ,a  
,,bill  ,to update dollar amount        
thresholds for certain currency         
transaction reports and suspicious      
activity reports1 to improve the sharing
 of suspicious activity reports within a
 financial group1 and for other         
purposes4  #a4 ,short title ,this ,act  
may be cited as the ,counter ,terrorism 
and ,illicit ,finance ,act4  #b4        
,updating thresholds for certain        
currency transaction reports and        
suspicious activity reports  7a7        
,thresholds for certain currency        
transaction reports  7#a7 ,in general   
,not later than the end of the #ahj-;day
 period beginning on the date of the    
enactment of this ,act1 the ,secretary  
of the ,treasury shall revise           

regulations issued with respect to      
section #ecac of title #ca1 ,united     
,states ,code1 to update each #aj1jjj   
threshold amount in such regulations to 
#cj1jjj4  7#b7 ,threshold for reports   
relating to coins and currency received 
in nonfinancial trade or business       
,section #ecca of title #ca1 ,united    
,states ,code1 is amended by striking   
#aj1jjj each place such term appears in 
heading or text and inserting #cj1jjj4  
7b7 ,thresholds for suspicious activity 
reports ,not later than the end of the  
#ahj-;day period beginning on the date  
of the enactment of this ,act1 each     
,federal department or agency that      
issues regulations with respect to      
reports on suspicious transactions      
described under section #ecah7;g7 of    
title #ca1 ,united ,states ,code1 shall 
update each #e1jjj threshold amount in  
such regulations to #aj1jjj and each    
#b1jjj threshold amount in such         
regulation to #c1jjj4  7c7 ,updating the
 money services business definition     

thresholds ,not later than the end of   
the #ahj-;day period beginning on the   
date of the enactment of this ,act1 the 
,secretary of the ,treasury shall revise
 section #ajaj4ajj7;ff7 of title #ca1   
,code of ,federal ,regulations1 to      
update each #a1jjj threshold amount in  
such regulations to #c1jjj4  #c4        
,streamlining requirements for currency 
transaction reports and suspicious      
activity reports  7a7 ,review ,the      
,secretary of the ,treasury 7in         
consultation with ,federal law          
enforcement agencies1 the ,director of  
,national ,intelligence1 and the        
,federal functional regulators and in   
consultation with other relevant        
stakeholders7 shall undertake a formal  
review of the current financial         
institution reporting requirements under
 the ,bank ,secrecy ,act and its        
implementing regulations and propose    
changes to further reduce regulatory    
burdens1 and ensure that the information
 provided is of a high degree of        

usefulness to law enforcement1 as set   
forth under section #ecaa of title #ca1 
,united ,states ,code4  7b7 ,contents   
,the review required under subsection   
7a7 shall include a study of-- 7#a7     
whether the timeframe for filing a      
suspicious activity report should be    
increased from #cj days2  7#b7 whether  
or not currency transaction report and  
suspicious activity report thresholds   
should be tied to inflation or otherwise
 periodically be adjusted2  7#c7 whether
 the circumstances under which a        
financial institution determines whether
 to file a continuing suspicious        
activity report1 or the processes       
followed by a financial institution in  
determining whether to file a continuing
 suspicious activity report 7or both7   
can be narrowed2  7#d7 analyzing the    
fields designated as critical on the    
suspicious activity report form and     
whether the number of fields should be  
reduced2  7#e7 the categories1 types1   
and characteristics of suspicious       

activity reports and currency           
transaction reports that are of the     
greatest value to1 and that best        
support1 investigative priorities of law
 enforcement and national security      
personnel2  7#f7 the increased use of   
exemption provisions to reduce currency 
transaction reports that are of little  
or no value to law enforcement efforts2 
7#g7 the most appropriate ways to       
promote financial inclusion and address 
the adverse consequences of financial   
institutions de-risking entire          
categories of high-risk relationships1  
including charities1 embassy accounts1  
money service businesses 7as defined    
under section #ajaj4ajj7;ff7 of title   
#ca1 ,code of ,federal ,regulations71   
and correspondent banks2  7#h7 the      
current financial institution reporting 
requirements under the ,bank ,secrecy   
,act and its implementing regulations   
and guidance2 and  7#i7 such other items
 as the ,secretary determines           
appropriate4  7c7 ,report ,not later    

than the end of the one year period     
beginning on the date of the enactment  
of this ,act1 the ,secretary of the     
,treasury1 in consultation with law     
enforcement and persons subject to ,bank
 ,secrecy ,act requirements1 shall issue
 a report to the ,congress containing   
all findings and determinations made in 
carrying out the review required under  
subsection 7a74  #d4 ,sharing of        
suspicious activity reports within a    
financial group  7a7 ,in general  7#a7  
,sharing with foreign branches and      
affiliates ,section #ecah7;g7 of title  
#ca1 ,united ,states ,code1 is amended  
by adding at the end the following3     
7#e7 ,sharing with foreign branches1    
subsidiaries1 and affiliates  7,a7 ,in  
general ,not later than #ahj days after 
the date of the enactment of this       
paragraph1 the ,secretary of the        
,treasury shall issue rules permitting  
any financial institution with a        
reporting obligation under this         
subsection to share information on      

reports under this subsection with the  
institution's foreign branches1         
subsidiaries1 and affiliates for the    
purposes of combating illicit finance   
risks1 notwithstanding any other        
provision of law except subparagraph    
7,b74  7,b7 ,exception ,in issuing the  
regulations required under subparagraph 
7,a71 the ,secretary may not permit a   
financial institution to share          
information on reports under this       
subsection with a foreign branch1       
subsidiary1 or affiliate located in a   
jurisdiction that--  7i7 is subject to  
countermeasures imposed by the ,federal 
,government2 or  7ii7 the ,secretary has
 determined cannot reasonably protect   
the privacy and confidentiality of such 
information4  4  7#b7 ,notification     
prohibitions ,section #ecah7;g77#b77;,a7
 of title #ca1 ,united ,states ,code1 is
 amended-- 7,a7 in clause 7i71 by       
inserting after transaction has been    
reported the following3 or otherwise    
reveal any information that would reveal

 that the transaction has been reported1
 including materials prepared or used by
 the financial institution for the      
purpose of identifying and detecting    
potentially suspicious activity2 and    
7,b7 in clause 7ii71 by inserting after 
transaction has been reported1 the      
following3 or otherwise reveal any      
information that would reveal that the  
transaction has been reported1 including
 materials prepared or used by the      
financial institution for the purpose of
 identifying and detecting potentially  
suspicious activity14  7b7 ,rulemaking  
,not later than the end of the #ahj-;day
 period beginning on the date of        
enactment of this ,act1 the ,secretary  
of the ,treasury shall issue regulations
 to carry out the amendments made by    
this section4  #e4 ,fin,c,e,n no-action 
letters ,section #caj of title #ca1     
,united ,states ,code1 is amended-- 7#a7
 by redesignating subsection 7d7 as     
subsection 7e72 and  7#b7 by inserting  
after subsection 7c7 the following3  7d7

 ,no-,action letters with respect to    
specific conduct  7#a7 ,in general ,the 
,director of ,fin,c,e,n shall issue     
regulations to establish a process for  
the issuance of a no-action letter by   
,fin,c,e,n in response to an inquiry    
from a person or group of persons       
concerning the application of the ,bank 
,secrecy ,act1 the ,,usa ,,patriot ,act1
 or any other anti-money laundering and 
counter terrorist financing law or      
regulation to specific conduct1 which   
shall include a statement as to whether 
or not ,fin,c,e,n has any intention of  
taking an enforcement or other          
regulatory action against the person or 
group with respect to such conduct4     
7#b7 ,consultation ,in issuing the      
regulations described under paragraph   
7#a71 the ,secretary shall consult with 
the ,federal functional regulators and  
such other ,federal departments and     
agencies as the ,secretary determines   
appropriate4  7#c7 ,reliance on         
no-action letter  7,a7 ,liability       

,notwithstanding any other provisions of
 law1 except for paragraph 7#e77;,b71 a 
person described under subparagraph 7,b7
 who relies upon a no-action letter     
issued under this subsection in         
accordance with the provisions and      
findings of such letter shall not1 as a 
result1 be subject to any regulatory    
action or civil or criminal penalty     
under the ,bank ,secrecy ,act1 the ,,usa
 ,,patriot ,act1 or any other anti-money
 laundering and counter terrorist       
financing law or regulation with respect
 to the activity covered in the         
no-action letter4  7,b7 ,persons covered
 ,a person described in this paragraph  
is-- 7i7 any person involved in the     
specific conduct that is the subject of 
the no-action letter2 and  7ii7 any     
person involved in conduct which is     
indistinguishable in all its material   
aspects from the specific conduct that  
is the subject of the no-action letter4 
7#d7 ,fees  7,a7 ,in general ,the       
,director of ,fin,c,e,n shall develop a 

system to charge a fee for each request 
for a no-action letter made under this  
subsection in an amount sufficient1 in  
the aggregate1 to pay for the cost of   
carrying out this subsection4 ,such     
system shall provide for a lower fee for
 small business concerns and small      
financial institutions compared to other
 persons4  7,b7 ,notice and comment ,not
 later than #de days after the date of  
the enactment of this paragraph1 the    
,director of ,fin,c,e,n shall publish a 
description of the fee system described 
in subparagraph 7,a7 in the ,federal    
,register and shall solicit comments    
from the public for a period of #fj days
 after publication4  7,c7 ,finalization 
,the ,director of ,fin,c,e,n shall      
publish a final description of the fee  
system and implement such fee system not
 later than #cj days after the end of   
the public comment period described in  
subparagraph 7,b74  7#e7 ,modifying or  
rescinding a no-action letter  7,a7 ,in 
general ,the ,director of ,fin,c,e,n may

 modify or rescind any no-action letter 
issued under this subsection if-- 7i7 in
 light of changes in statute1           
regulations1 or policy the letter no    
longer sets forth the interpretation of 
,fin,c,e,n with respect to the content  
of the letter2 or  7ii7 any fact or     
statement submitted in the original     
inquiry is found to be materially       
inaccurate or incomplete4  7,b7 ,no     
reliance on rescinded letter ,paragraph 
7#c7 shall not apply to the any actions 
taken after the date that a no-action   
letter is rescinded4  7,c7 ,retroactive 
modification or rescission ,a no-action 
letter may be modified or rescinded     
retroactively only with respect to one  
or more parties to the original inquiry 
and only if the ,director of ,fin,c,e,n 
determines that--  7i7 a fact or        
statement in the original inquiry was   
materially inaccurate or incomplete2    
7ii7 the requestor failed to notify in  
writing ,fin,c,e,n of a material change 
to any fact or statement in the original

 request2 or  7iii7 a party to the      
original inquiry acted in bad faith when
 relying upon the no-action letter4     
7,d7 ,notice of modification and        
rescission ,in the case that the        
,director of ,fin,c,e,n modifies or     
rescinds a no-action letter under this  
subsection1 the ,director of ,fin,c,e,n 
shall--  7i7 provide notice of such     
modification or rescission2  7ii7       
establish a reasonable time period1 of  
not less than #ij days1 in which        
impacted persons may update their       
anti-money laundering programs or       
processes to achieve compliance with the
 ,bank ,secrecy ,act1 the ,,usa         
,,patriot ,act1 or any other anti-money 
laundering and counter terrorist        
financing law or regulation4  7#f7      
,definitions ,for purposes of this      
subsection3 7,a7 ,bank ,secrecy ,act    
,the term ,bank ,secrecy ,act means--   
7i7 section #ba of the ,federal ,deposit
 ,insurance ,act2  7ii7 chapter #b of   
title ,i of ,public ,law #ia-ejh2 and   

7iii7 subchapter ,,ii of chapter #ec of 
this title4  7,b7 ,federal functional   
regulator ,the term ,federal functional 
regulator has the meaning given that    
term under section #ecab of title #ca1  
,united ,states ,code4  7,c7 ,small     
business concern ,the term small        
business concern has the meaning given  
under section #c of the ,small ,business
 ,act4  4  #f4 ,requiring ,treasury to  
take a more prominent role in           
coordinating ,,aml_/,,cft policy and    
examinations across the ,government  7a7
 ,priorities ,not later than nine months
 after the date of the enactment of this
 ,act1 and at least annually thereafter1
 the ,secretary of the ,treasury1 acting
 through the ,office of ,terrorism and  
,financial ,intelligence and the        
,financial ,crimes ,enforcement         
,network1 in consultation with relevant 
,federal law enforcement1 the ,director 
of ,national ,intelligence1 and any     
other ,federal departments and agencies 
that the ,secretary of the ,treasury    

determines appropriate1 shall establish 
and make public its priorities for      
,u4,s4 anti-money laundering and counter
 terrorist financing policy4  7b7       
,supervision and examination ,the       
incorporation by financial institutions 
of the priorities established pursuant  
to subsection 7a7 into the programs     
established by those financial          
institutions to meet obligations under  
the ,bank ,secrecy ,act1 the ,,usa      
,,patriot ,act1 and other anti-money    
laundering and counter terrorist        
financing laws and regulations shall    
form the basis on which the financial   
institutions are supervised and examined
 for compliance with those obligations4 
7c7 ,rule of construction ,nothing in   
subsection 7a7 may be construed as      
releasing financial institutions from   
the requirement to comply with          
obligations under the ,bank ,secrecy    
,act and other ,federal laws and        
regulations4  7d7 ,report ,not later    
than nine months after the date of      

enactment of this ,act1 the ,secretary  
of the ,treasury 7in consultation with  
,federal law enforcement agencies1 the  
,director of ,national ,intelligence1   
and the ,federal functional regulators7 
shall submit to the ,committee on       
,financial ,services of the ,house of   
,representatives and the ,committee on  
,banking1 ,housing1 and ,urban ,affairs 
of the ,senate a report containing--    
7#a7 an analysis of the ,secretary of   
the ,treasury's delegation of           
examination authority under the ,bank   
,secrecy ,act1 including the adequacy of
 the ,department of the ,treasury's     
resources1 capacity1 expertise1 and     
ability to effectively carry out the    
purposes of the ,bank ,secrecy ,act2    
7#b7 an examination of whether the      
,secretary should de-delegate that      
authority with regard to certain        
financial institutions2 and  7#c7       
legislative1 administrative1 and other  
recommendations to strengthen the       
,department of the ,treasury's authority

 to ensure an effective ,u4,s4          
anti-money laundering and counter       
terrorist financing regime4  #g4        
,encouraging the use of technological   
innovations ,section #ecah7;h7 of title 
#ca1 ,united ,states ,code1 is amended  
by adding at the end the following3     
7#d7 ,encouraging the use of            
technological innovations  7,a7 ,in     
general ,the ,secretary of the ,treasury
 shall1 in carrying out this subsection1
 encourage but not require the use of   
technological innovations that improve  
anti-money laundering programs described
 under paragraph 7#a74  7,b7 ,safe      
harbor ,an anti-money laundering program
 that meets the minimum requirements    
described under paragraph 7#a7 and any  
minimum standards issued pursuant to    
paragraph 7#b71 shall not violate the   
requirements of this subsection by      
reason of any technological innovation  
used to carry out such program4  7,c7   
,rule of construction ,nothing in       
subparagraph 7,a7 may be construed as   

releasing financial institutions from   
the requirement to comply with existing 
obligations under the ,bank ,secrecy    
,act and other ,federal laws and        
regulations4  4  #h4 ,assessing the     
usefulness of ,bank ,secrecy ,act       
reporting  7a7 ,annual report ,not later
 than one year after the date of        
enactment of this ,act1 and annually    
thereafter1 the ,attorney ,general1 in  
consultation with ,federal law          
enforcement agencies and the ,director  
of ,national ,intelligence1 shall1 to   
the extent practicable at the discretion
 of the ,attorney ,general1 provide the 
,secretary of the ,treasury with        
statistics1 metrics1 and other          
information on the use of such data1    
including--  7#a7 the extent to which   
such data is used for terrorism versus  
non-terrorism related investigations    
and1 with respect to such non-terrorism 
related investigations1 the most common 
types of laws to which such             
investigations relate2  7#b7 the        

frequency with which such data contains 
actionable information which leads to   
further law enforcement procedures1     
including the use of a subpoena1        
warrant1 or other legal process2 and    
7#c7 information on the extent to which 
arrests1 indictments1 convictions1 or   
plea bargains of actors result from the 
use of such data4  7b7 ,use of report   
information ,the ,secretary of the      
,treasury shall utilize the information 
reported under subsection 7a7-- 7#a7 to 
help assess the usefulness of ,bank     
,secrecy ,act reporting to law          
enforcement2  7#b7 to enhance feedback  
and communications with financial       
institutions and other entities subject 
to ,bank ,secrecy ,act requirements2 and
  7#c7 for such other purposes as the   
,secretary determines appropriate4  #i4 
#ah-,month ,enforcement ,safe ,harbor of
 ,,cdd ,rule ,no person shall be liable 
for any violation of the final rule of  
the ,department of the ,treasury titled 
,customer ,due ,diligence ,requirements 

for ,financial ,institutions 7,,cdd     
rule7 published ,may #aa1 #bjaf 7#ha    
,fed4 ,reg4 #bicig71 during the         
#ah-month period beginning on ,may #aa1 
#bjah1 so long as such person has made a
 good faith effort to comply with such  
requirements4  #aj4 ,studies and reports
  7a7 ,beneficial ownership ,not later  
than #b years after the date of         
enactment of this ,act1 the ,comptroller
 ,general of the ,united ,states shall  
conduct a study and submit to the       
,congress a report--  7#a7 evaluating   
the effectiveness of the collection of  
beneficial ownership information under  
the ,,cdd rule 7as defined under section
 #i71 including--  7,a7 whether law     
enforcement agencies have had timely    
access to the information2  7,b7 the    
utility of such information in law      
enforcement investigations or           
prosecutions2  7,c7 an analysis of the  
reporting burden placed on financial    
institutions versus the utility of such 
information being made available to law 

enforcement2 and  7,d7 whether further  
legislation is required to reduce       
regulatory burdens or increase the      
utility and timely access of such       
information to law enforcement2  7#b7   
assessing the effectiveness of          
incorporation practices implemented     
under the ,,cdd rule4  7b7              
,comprehensive cost-,benefit analysis   
,not later than #b years after the date 
of enactment of this ,act1 the          
,comptroller ,general of the ,united    
,states shall conduct a study and submit
 to the ,congress a report--  7#a7      
providing a comprehensive quantitative  
and qualitative estimate of the         
annualized costs to the private sector  
to comply with the statutory and        
regulatory requirements of the ,bank    
,secrecy ,act and related anti-money    
laundering laws and regulations2  7#b7  
providing a comprehensive qualitative   
and quantitative analysis of the        
effectiveness of the current anti-money 
laundering and counter terrorist        

financing framework in preventing1      
detecting1 and prosecuting terrorist and
 illicit financing2  7#c7 providing a   
comprehensive qualitative and           
quantitative analysis of the benefits   
and costs to both the private sector and
 the ,government of the private sector's
 compliance with the statutory and      
regulatory requirements of the ,bank    
,secrecy ,act and related anti-money    
laundering laws and regulations2 and    
7#d7 examining the costs borne and      
effect on access to financial services  
for consumers and customers as a result 
of financial institutions compliance    
with the statutory and regulatory       
requirements of the ,bank ,secrecy ,act 
and related anti-money laundering laws  
and regulations4  #aa4 ,definitions ,for
 purposes of this ,act3 7#a7 ,bank      
,secrecy ,act ,the term ,bank ,secrecy  
,act means--  7,a7 section #ba of the   
,federal ,deposit ,insurance ,act2  7,b7
 chapter #b of title ,i of ,public ,law 
#ia-ejh2 and  7,c7 subchapter ,,ii of   

chapter #ec of title #ca1 ,united       
,states ,code4  7#b7 ,federal functional
 regulator ,the term ,federal functional
 regulator has the meaning given that   
term under section #ecab of title #ca1  
,united ,states ,code4  7#c7 ,financial 
institution ,the term financial         
institution has the meaning given that  
term under section #ecab of title #ca1  
,united ,states ,code4