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BSA Modifications Included in National Defense Authorization Act

On January 2, 2021, the United States Congress enacted the National Defense Authorization Act for 2021 (H.R. 6395) (NDAA of 2021 or the Act), which passed both the House of Representatives and Senate in early December but was vetoed by the President in late December, by voting to override the President’s veto on the legislation. The NDAA of 2021 includes banking industry backed provisions to modernize, enhance, and reform anti-money laundering processes as outlined in […]

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NEW CUSTOMER DUE DILIGENCE AND BENEFICIAL OWNERSHIP EXAMINATION PROCEDURES

On May 11, 2018, the effective date of the Beneficial Ownership requirements, the Federal Financial Institutions Examination Council (FFIEC) issued new examination procedures on the final rule, “Customer Due Diligence Requirements for Financial Institutions,” issued by the Financial Crimes Enforcement Network (FinCEN) on May 11, 2016. The examination procedures apply to banks, savings and loan associations, savings associations, credit unions, and branches, agencies, and representative offices of foreign banks. The new examination procedures replace those […]

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FinCEN Proposes Rule

On July 30, 2014, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that, if finalized, will amend the Bank Secrecy Act regulations to enhance customer due diligence (CDD) requirements imposed on financial institutions (i.e. banks, brokers and dealers in securities, mutual funds, and future commission merchants and introducing brokers in commodities).  In an effort to increase financial transparency and protect the financial system from […]

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