WASHINGTON–The Defense Credit Union Council has sent a letter to the U.S. Treasury expressing its concern over FinCEN’s Nov. 28 alert on “Cross-Border Funds Transfers Involving Illegal Aliens.”
While DCUC said it supports efforts to combat illicit finance, DCUC President/CEO Anthony Hernandez said the lack of clearer guidance, could “unintentionally disrupt lawful transactions made by servicemembers, veterans, and their families, many of whom rely on cross-border transfers during deployments and relocations.”
Hernandez further warned in the letter that the alert’s broad scope and limited clarity may lead financial institutions to “over-comply” by flagging or blocking legitimate transfers, filing unnecessary SARs, or restricting routine remittances.
Key Measures Urged
To prevent such disruptions, Hernandez urged Treasury to adopt three key measures:
- Targeted Guidance
- Clarification for Military Transfers
- Regulatory Safe Harbor
“DCUC stands ready to assist Treasury and FinCEN in clarifying the alert’s implementation to ensure national security goals are met without disrupting lawful financial support for servicemembers, veterans, and their families,” the letter states.
The full letter can be found here.
