To Whom It May Concern:

We appreciate the opportunity to comment on the request for information and comment on the Review of Bank Secrecy Act Regulations and Guidance. The Financial Crimes Enforcement Network’s effort to streamline, modernize, and update the Bank Secrecy Act (BSA) is an excellent opportunity to improve the financial regulatory framework in the United States. The Cato Institute is a public policy research organization dedicated to the principles of individual liberty, limited government, free markets, and peace, and the Center for Monetary and Financial Alternatives focuses on identifying, studying, and promoting alternatives more conducive to a stable, flourishing, and free society. The opinions we express in this comment letter are our own.

There are many ways to modernize the anti-money laundering and countering the financing of terrorism (AML/CFT) regime in the United States, ranging from discrete reforms to agency regulations to a complete repeal of the BSA. However, in this letter, we will limit our comments to questions B.3, B.7, and C.ii.14 in FinCEN’s request for information.