The Financial Crimes Enforcement Network (FinCEN) has proposed the cross-border electronic transmittal of funds (CBETF) rule in an effort for financial institutions and money service businesses (MSBs) to assist law enforcement in detecting transnational crime, multinational drug cartels, terrorist financing, and international tax evasion.
The proposed rule would require financial institutions and MSBs that are either the first U.S. institution to receive an incoming CBETF or the last U.S. financial institution to process an outgoing CBETF to report such transactions to FinCEN.
A MSB must report any CBETF of $1,000 or more, while financial institutions must report all CBETFs regardless of the amount. All reports of a CBETF of $3,000 or greater must include the taxpayer’s identification number (TIN), if available. To meet the reporting requirements, the financial institution and MSB should electronically send a copy of the funds transmittal order to FinCEN. In addition, FinCEN is proposing a requirement for all financial institutions to annually report a list of TINs of individuals who transmitted or received a CBETF.
Current regulations require that financial institutions and MSBs maintain and make available CBETF information; however, there is no current requirement to report this information.
For more information about the CBETF rule or our financial institution advisory services, contact the expert listed below at PYA, (800) 270-9629.