WASHINGTON— America’s Credit Unions is urging the Financial Crimes Enforcement Network to significantly increase reporting thresholds for key anti-money laundering filings, arguing current requirements are outdated and impose unnecessary burdens on credit unions.
In a comment letter dated April 23, the group called on FinCEN to modernize thresholds for Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), which currently require reporting of cash transactions over $10,000 and suspicious activity involving at least $5,000.
According to America’s Credit Unions, those thresholds have not kept pace with inflation or changes in transaction volumes and technology, resulting in large volumes of reports that provide limited value to law enforcement while increasing compliance costs for financial institutions.
The Recommendations
The letter recommends:
- Raising the CTR threshold to $30,000
- Increasing the SAR threshold to $10,000
- Indexing both thresholds to inflation to prevent future erosion of their effectiveness
America’s Credit Unions said in the letter that these changes would allow credit unions to better align resources with higher-risk activity, rather than filing large numbers of low-value reports.
The trade group also emphasized that modernizing thresholds would improve the overall effectiveness of the Bank Secrecy Act framework by enabling institutions to focus on identifying and reporting truly suspicious behavior, rather than meeting what it characterized as outdated, “check-the-box” requirements.
Additional Reforms Urged
In addition to threshold changes, the letter urged FinCEN to consider broader reforms, including simplifying reporting processes and adopting more risk-based approaches for low-risk, long-standing members.
America’s Credit Unions said such updates would reduce regulatory burden while maintaining strong safeguards against illicit finance, adding that current reporting requirements often divert resources away from detecting higher-risk activity.
The letter was submitted as FinCEN considers broader updates to anti-money laundering and countering the financing of terrorism (AML/CFT) rules, part of a wider Treasury effort to modernize the regulatory framework and improve the usefulness of financial intelligence.
America’s Credit Unions said in the letter that updating SAR and CTR thresholds is a “critical step” toward a more effective and efficient system that better serves both financial institutions and law enforcement.
The full letter can be found here.
Simpson Meets With HFSC Subcommittee Chair
Separately, America’s Credit Unions President and CEO Scott Simpson met with House Financial Services Subcommittee on Financial Institutions Chairman Andy Barr (R-KY). As the CU Daily reported here, Barr is a co-sponsor of two privacy bills that were introduced this week, the GUARD Financial Data Act and SECURE Data Act. The bills seek to create a national data security standard and contain several principles America’s Credit Unions said it wants to see part of any data security legislation.
The trade group said it also reiterated the need for maintaining the FY26 funding in FY27 for the CDFI Fund. Barr previously co-sponsored, along with a bipartisan group of Senators, legislation to provide increased transparency to the Fund.
“We thank Chairman Barr for taking time to meet with America’s Credit Unions and discuss priority issues,” Simpson said in a statement. “He is always willing to consider credit unions’ perspective, and we greatly appreciate his work to reduce regulatory burdens and ensure consumers have access to safe, affordable financial services.”
