Melissa Hoeft

audit

What is a common finding TCA sees in exempting eligible customers from CTR reporting?

Q&A / By

Answer: During independent audits, TCA tests for initial and annual due diligence reviews of exempt customers. There are four requirements for a Phase II exemption.  Five transactions that exceed reporting thresholds in a 12-month period. The customer has a transaction account for at least 2 months. The customer is organized in a U.S. State. The …

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fraud being stopped

FinCEN Guidance on Medical Scams and COVID-19

AMS Model Reviews, BSA/AML, Special Release / By

As we continue to adjust with the evolving pandemic, FinCEN published two documents to keep awareness high. The May 18, 2020 Notice provides a current update to meet the various BSA reporting, recordkeeping and monitoring requirements.  Here are a few of the key points: BSA Reporting Requirements – As noted in TCA’s earlier article BSA …

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money, finance, wealth

Important CTR Update – Compliance Date Moves From February 1, 2020 to September 1, 2020

Special Release / By

TCA’s January 21, 2020 “CTR 101 Webinar” highlighted one key change to the FinCEN CTR report – the evolving expectations on how to complete Part I Item 2. The original October 1, 2019 Notice published required a February 1, 2020 compliance date. The January 17, 2020 Notice extends the compliance date for files to September …

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hemp business

FinCEN Issues Guidance on Providing Financial Services to Hemp-Related Businesses

Special Release / By

FinCEN and the regulators kicked off the holiday season by providing the industry with some clarification on the BSA implications of banking hemp-related businesses. In the News Release and Guidance, FinCEN said: “Because hemp is no longer a Schedule I controlled substance under the Controlled Substances Act, banks are not required to file a Suspicious …

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security icon and privacy concept

314(a) and 314(b) Information Sharing: Is there a Difference?

In Depth / By

The goal of my article is to help BSA staff have a clearer understanding of the differences between mandatory and voluntary information sharing. TCA’s BSA Action Team (BAT) wants to point out some key observations based on our BSA audits. In BSA, information requests are commonly referred to as sections 314(a) and 314(b) of the …

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BAT CHAT

What do CDD and EDD Mean? Part II: Enhanced Due Diligence

BAT Chat / By ,

The expectation for enhanced due diligence did not change with the passing of the 5th BSA pillar. However, examiner expectations for enhanced due diligence (EDD) continue to evolve because it is a critical component of your bank’s BSA Program. TCA® first addressed the EDD topic in a 2015 In Depth article. The November 2018 BAT …

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certificate of deposit

FinCEN Issues Extension of Exceptive Relief for Certificate of Deposit and Loan Renewals

Special Release / By

The top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges …

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