Special Measures on Certain Institutions of Primary Money Laundering Concerns

SIFMA provides comments to the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) on the imposition of special measures against Halawi Exchange Co., Kassem Rmeiti & Co. for Exchange, and Liberty Reserve S.A. as financial institutions of primary money laundering concern, RIN 1506-AB21, RIN 1506-AB22, RIN 1506-AB23. SIFMA supports FinCEN’s efforts to detect and prevent money laundering and the financing of terrorist activity, whether through the identified financial institutions or otherwise. To that end, SIFMA respectfully submits these clarifications and modifications with respect to the proposed rules would better facilitate compliance with the special measures and, through consistency in the information provided to FinCEN by covered financial institutions, effective monitoring by FinCEN of the parties at issue.