The proposal would have two significant effects on depository institutions that wire funds across the border. First, depository institutions would have an affirmative duty to report all CBEFTs to FinCEN. Currently, institutions must make that information available upon a valid legal request from the Government, but there is no duty to report. Second, financial institutions would be required to file an annual report with a list of the TIN for each accountholder who transmitted or received a CBETF during that calendar year.
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