The U.S. operations of internationally headquartered banks underwrote more than $11 trillion in U.S. financing over the last four years, according to a new economic impact study by the Institute of International Bankers (IIB), which reaffirms the vital role international banks play in the U.S. economy. This represents more than 40% of the $28 trillion in U.S. financing raised since 2020, including 36% of U.S.-headquartered companies’ U.S. issuance.

On October 4, the IIB submitted a letter to the Federal Reserve Board and Office of the Comptroller of the Currency concerning the agencies’ joint proposal on AML program requirements, part of efforts to implement the Anti-Money Laundering Act of 2020. In the letter, the IIB raises its concerns about the proposed requirement that the U.S. operations of international banks onshore significant portions of their anti-money laundering and countering the financing of terrorism (AML/CFT) programs that are currently conducted offshore, a change which would be extraordinarily burdensome, impracticable to implement in the short- and medium-term, and potentially infeasible. Its comments to the banking agencies echo comments that it recently submitted to FinCEN.

The IIB advocated for critical changes to a proposed rule implementing the Anti-Money Laundering (AML) Act of 2020 in a comment letter to the Financial Crimes Enforcement Network (FinCEN) yesterday. The proposed rule would require the U.S. operations of international banks to onshore significant portions of their anti-money laundering and countering the financing of terrorism (AML/CFT) programs that are currently conducted offshore, a change which is extraordinarily burdensome, impracticable to implement in the short- and medium-term, and potentially infeasible.