September 3, 2024
Chief Lynn Malerba, Treasurer US Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, D.C. 20220 Refer to: Docket Number FINCEN-2024-0013
Re: Comments on Proposed Revisions to Anti-Money Laundering and Countering the Financing of Terrorism Programs
Dear Chief Malerba:
On behalf of the Indian Gaming Association’s (“IGA”) membership, we are seeking clarification on the submission extension for the proposed revision to the Anti-Money Laundering (“AML”) and Countering the Financing of Terrorism (“CFT”) programs published by the Financial Crimes Enforcement Network (“FinCEN”) in the Federal Register on July 3, 2024. Specifically, based upon the date of the Tribal Consultation we presume that the deadline has been extended, but we would appreciate the assurance that it has been extended from September 3, 2024, to October 18, 2024, for Tribal Nations. We also strongly suggest that this timeline be even further extended to November 30, 2024, in order to provide ample time for IGA members and the rest of Indian Country to disseminate further notice and information regarding the proposed revisions so that the public may submit more informed comments. IGA expects to move forward under the assumption that the comment deadline has been extended to the October 18 th date that was offered in the Dear Tribal Leaders letter distributed on August 16, 2024. Should this be the case, we would also hope that the comments received during the Tribal Consultation period pursuant to Executive Order 13175 shall receive the same weight as those received prior to the September 3 rd deadline. In preparation for the Tribal Consultation that shall be held on September 13, 2024, we wish to provide you with an overview of our comments on the revisions to the AML and CFT programs as they apply to financial institutions. Our concerns largely focus on the clarity of the language in the proposed § 1021.210 and the increase in the burden that these revisions have the potential to place on Tribal governments. Further, IGA would like to re-emphasize that in order for the Tribal Consultation period to be most effective, we strongly recommend that FinCEN extend the comment submission deadline for this proposed rulemaking to November 30, 2024.
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