FinCEN Issues Final Rule for Beneficial Ownership Reporting
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BSA/AML
How do I complete Part II (Amounts and Dates) on a continuing activity suspicious activity report (SAR) if the transaction took place on a single date? Do I include the investigation range from the previous filing?
Answer: The date field in Part II should only cover the date range of activity determined to be suspicious, not the investigation range. If transaction occurred on a single date, the “To” field is left blank. Describe the time period of the investigation in the narrative.
When dispositioning alerts from our automated BSA/AML monitoring system, how much information is enough?
Answer: TCA continues to see examiner scrutiny on alert resolution. When documenting a response to an alert, it does not need to be as in-depth as an investigation narrative; however, it must explain the who, what, where, when, why, and how. This creates continuity for other BSA staff, examiners, and auditors to understand how you …
New Hemp-related Business Guidance
On June 29, 2020, FinCEN published FIN-2020-G001 providing guidance for obtaining due diligence information for hemp-related businesses. The BSA industry has wrestled with cannabis and its derivative rules since FinCEN’s initial 2014 guidance for banking marijuana-related businesses. Between 2014 and 2018, hemp was equated with marijuana since both are derived from the same plant. However, …
FinCEN Guidance on Medical Scams and COVID-19
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 …
Preparing a Bank Secrecy Act Risk Assessment
Welcome to TCA’s BSA Back to Basics article series! Each month, our BSA experts will explore a section of the FFIEC BSA/AML Exam Manual, analyze the regulatory requirements, and offer insights to common findings in exams and audits. We will share best practices to help your BSA program continue to evolve. The first section of …
BSA Compliance & COVID-19: FinCEN & SBA Updates
Over the past month, every facet of our lives has dramatically changed. Shelter-in-place orders, rotating bank staff, lobby closures, government stimulus programs and a myriad of regulatory updates have stretched risk management resources. TCA has received many questions from clients asking for our interpretation of guidance that has been issued in response to these regulatory …
Legislative and Regulatory BSA/AML Changes
Despite the collective efforts of law enforcement and BSA risk managers across the country, the United States is not doing the best job of finding effective and efficient ways to combat money laundering. Regulatory and legislative efforts, which are the truly meaningful actions that could be taken, are currently being worked on in Washington. A …
Examiners Stress Independent Audit Critical to BSA Success
On July 22, 2019, the prudential regulators issued FIL-43-2019 making a joint statement on BSA/AML risk-based approaches in examinations. TCA’s BAT reviewed the statement and took away three key points: transparency, risk assessment and independent audit. Transparency – The statement states: “This statement is intended to improve transparency into the risk-focused approach used for planning …
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Quality Assurance Monitoring for BSA/AML Compliance Programs
When your institution is examined for compliance with any law or regulation, the measure of your efforts will be based on your ability to self-identify and self-correct any deficiencies. Ongoing monitoring of key processes helps to ensure that any errors or warning flags are identified early. Monitoring is a required element of a compliance management …
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