A major source of the difficulties Overseas Americans have experienced with opening and maintaining bank and other financial accounts in the United States in recent years has been regulation and guidance to banks intended to fight money laundering and financing of terrorism.
This regulatory framework has not been a problem for Overseas Americans alone. It has also been widely criticized as ineffective in achieving its main objective of protecting the financial system from illicit activity. At the same time, compliance costs for banks have often been excessive.
Against this background, the Financial Crimes Enforcement Network (FinCEN) requested comments on ways to streamline and update its regulatory regime with a view to making it both more efficient and cost-effective.
In response to this request AARO President Doris Speer and Banking Committee Chair Paul Atkinson have submitted a comment which can be downloaded here: