TCH filed a joint comment letter with the ABA to FinCEN on sanctions under §311 of the USA PATRIOT Act against Halawi Exchange, Kassem Rmeiti & Co., and Liberty Reserve. In the letter, the Associations urge FinCEN to revise reporting requirements on Halawi and Kassem and finalize them to replace the reporting requirements that are currently in place. The letter suggests that the reporting requirements should be revised in several ways: (i) the rule must be clear about which transactions are covered; (ii) identification of the parties should be limited to the information that is included in the payment order under FinCEN’s travel rule; (iii) FinCEN should implement the proposal to limit the concept of “legal capacity” to the parties that are listed on the transaction instruction; (iv) FinCEN should follow the timing rules for suspicious activity reports (“SARs”) in determining when information should be reported; and (v) the proposal should be revised to reflect that it misstates the actual burden of the requirement.