Melissa Hoeft

hemp business

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

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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BAT CHAT

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

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

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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