The Financial Technology Association (FTA) submitted a response to a request for information regarding a review of Bank Secrecy Act regulations and guidance issued by the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN). The letter reads in part:

“Many FTA members are subject to BSA requirements, and all are at the front lines of financial services innovation and digital customer engagement. It is this spirit of innovation that allows our members to provide services in ways that traditional financial institutions cannot and reach underserved or unbanked populations and bring them into the formal financial sector. Because our members deal with the most sensitive aspect of our customers’ lives, their finances, FTA members accordingly develop robust BSA compliance teams and policies that apply a risk-based framework to novel scenarios and are active leaders advancing modern compliance solutions. Whether in the context of lending, payments, buy-now pay-later, investment, or robo-advisory services, FTA members are engaged in the most timely and relevant areas of BSA application.

“More specifically, FTA members frequently rely on the most innovative technologies and customer engagement channels to offer services, which means they deal with the most timely issues relating to BSA compliance on a regular basis. FTA members are leaders in using new technologies to satisfy compliance requirements giving them a key perspective in understanding how existing AML regulatory frameworks facilitate or impede the development of promising regtech or related compliance solutions. Against this backdrop, FTA respectfully submits the following recommendations to advance innovative, effective, and efficient AML compliance frameworks and solutions.

“Importantly, FTA members do not operate in a vacuum. Many of our members partner with more traditional financial institutions of all sizes, so the regulatory intersection between established financial institutions and FTA members is also an area of deep interest and innovation, including with respect to AML compliance. Additionally, many fintech firms are actively seeking and securing bank and related charters, which further increases the importance of the topics raised in this request and the recommendations provided below.”

Read the full comment letter here.