Alert September 28, 2010

FinCEN Proposes Rule That Would Require Reporting of Cross-Border Electronic Transmittals of Funds

FinCEN proposed a rule that would require certain banks and money services business to report to FinCEN records of transmittal orders associated with certain cross-border electronic transmittals of funds (“CBETF”).  Existing regulations already require that these financial institutions maintain and make available, but not affirmatively report, essentially the same CBETF information.  The proposed rule would also require banks to annually file a list of taxpayer identification numbers of accountholders who transmitted or received a CBETF.  A detailed discussion of the proposed rule will be provided in a future edition of the Alert.