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WASHINGTON-The Financial Crimes Enforcement Network (FinCEN) began a study in late August of financial institutions, including credit unions, to determine the costs of filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), as well as the use of exemptions for the CTR process. Surveys were delivered via e-mail and fax, explaining that the results would help to improve the effectiveness of Bank Secrecy Act reporting requirements to the benefit of financial institutions and the federal government’s anti-money laundering efforts. FinCEN received over 12 million CTRs last year, and the agency’s best estimate is that 30% of those were exempt as recurring customer transactions. The excess forms serve little purpose for law enforcement activities and impose substantial extraneous costs on the financial institutions and the agency, according to FinCEN. The streamlining and increased effectiveness effort arose out of requirements in the USA PATRIOT Act and the National Money Laundering Strategy, which directs the Treasury Secretary to conduct the study by the end of October 2002. FinCEN’s survey was developed in conjunction with Deloitte and Touche with input from the federal banking agencies.

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