To Whom It May Concern:

My name is Nicholas Anthony and I am a Research Fellow at the Cato Institute’s Center for Monetary and Financial Alternatives. I appreciate the opportunity to provide input to assist the Financial Crimes Enforcement Network (FinCEN) in its effort to modernize the Bank Secrecy Act. 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 to centralized, bureaucratic, and discretionary monetary and financial regulatory systems. The opinions I express here are my own.

Shifting the focus of the Bank Secrecy Act and its related policies (henceforth, the Bank Secrecy Act regime) from compliance theatre to risk-based policy is a welcome change. However, the changes proposed by FinCEN today leave much to be desired.