In January, the Government Accountability Office released a report, in response to Congress’ request, titled Internal Remittances – Money Laundering Risks and Views on Enhanced Customer Verification and Recordkeeping Requirements. This was initiated from a 2015 Senate bill, the Remittance Status Verification Act of 2015.  While the Act did not proceed further, it would have required remittance transfer providers (including credit unions) to, before initiating a transfer, request from the sender of an international remittance transfer proof of the sender’s status under U.S. immigration laws.

The Act was preceded by FinCEN’s proposed rulemaking in 2006, and 2010, requiring verification of the identity of the sender.

What does this mean?

Right now, nothing…

And with FinCEN’s speed of enacting rules, probably nothing for a while…

However, if Congress keeps its fingers in the game, we may see additional BSA requirements for remittance transfers in the not-so-distant future.