From: Don H Kelly [mailto:dkelly@bankonblv.com]
Sent: Thursday, February 03, 2005 1:34 PM
To: Comments
Subject: EGRPRA BURDEN REDUCTION COMMENT
This response is to your request for comments regarding regulations that
are outdated, unnecessary, or unduly burdensome, and especially Money
Laundering.
The current limit of $10,000 for currency transactions, and $3,000 for
monetary instruments should be increased significantly. Our bank would
recommend limits of $50,000 and $20,000 respectively.
The reasons for our recommendation are:
1. The current levels are not indicative of “large” transactions in
today’s economy.
2. A significant cost is imposed on our bank to monitor transactions
under the current guidelines.
3. It is extremely unlikely that any federal agency would actively
pursue a customer who was determined to have conducted money laundering
for small amount (for instance, $15,000).
4. The government should direct its efforts, and that required of banks,
to more significant transactions and perpetrators of money laundering
activities.
Don H. Kelly
Executive Vice President
The Bank of Las Vegas
Las Vegas, New Mexico
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