Archive

FINCEN STATEMENT ON BSA ENFORCEMENT AND JOINT STATEMENT ON PEP DUE DILIGENCE

On August 18, the Financial Crimes Enforcement Network (FinCEN) issued Financial Crimes Enforcement Network (FinCEN) Statement on Enforcement of the Bank Secrecy Act, which “sets forth its approach to enforcing the rules and regulations within the BSA” and outlines factors FinCEN uses when determining enforcement response to actual or possible violations. The Statement notes, when a violation, or potential violation of the BSA or implementing regulations occurs, FinCEN has authority to take various actions including […]

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FINCEN PUBLISHES NEW CDD FAQS

On August 3, 2020, the Financial Crimes Enforcement Network (FinCEN) published three new Frequently Asked Questions (FAQs) regarding Customer Due Diligence (CDD) requirements for financial institutions. The new FAQs clarify the regulatory requirements related to: Obtaining customer information; Establishing a customer risk profile; and Performing ongoing monitoring of the customer relationship. The new FAQs are in addition to those that were published on: July 19, 2016; and April 3, 2018. For further information regarding customer […]

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EXTENSION OF LIMITED EXCEPTION TO BENEFICIAL OWNERSHIP RULE

On August 8, 2018 Financial Crimes Enforcement Network (FinCEN) announced a 30-day extension to the limited exception to the Beneficial Ownership Rule   On May 16, 2018, FinCEN issued a 90-day limited exceptive relief to covered financial institutions from the obligations of the Beneficial Ownership Rule for Legal Entity Customers (Beneficial Ownership Rule) for certain financial products and services (i.e., certificate of deposit or loan accounts) that were established before the Beneficial Ownership Rule’s Applicability […]

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SAR- E-FILING SYSTEM CHANGES

As promised earlier this month on July 27th, 2018, FinCEN released the following changes to the BSA E-Filing System production environment: FinCEN posted the new discrete entry form version (v1.2) of the FinCEN Suspicious Activity Report (SAR) for download/submission; FinCEN began accepting batch files containing the new FinCEN SAR in the new FinCEN 2.0 XML schema format; FinCEN updated the FinCEN CTR XML batch schema to prohibit certain unwanted characters/formatting for all elements values in […]

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FINCEN ISSUES BENEFICIAL OWNERSHIP DELAY IN REGARDS TO RENEWALS AND ROLLOVERS

On Wednesday, May 16th, FinCEN issued a ruling that provides covered institutions a 90-day period of limited exceptive relief to their requirements under the Beneficial Ownership Rule. This exception applies to products and services that are set to automatically rollover or renew (CD or loan accounts) that were established before May 11, 2018. This exception came just five days after the mandatory compliance date of the Beneficial Ownership Rule had passed. This relief period will […]

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