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 […]
Category: FinCEN
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 […]
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 […]
FINCEN RELEASES LONG AWAITED CDD FAQS
The wait is finally over as FinCEN released Frequently Asked Questions to the CDD requirements published on May 11, 2016. In the nearly two years since being published, we have also seen amendments to the requirements on September 29, 2017 ahead of the May 11, 2018 mandatory compliance date. The 24-page document includes 37 questions ranging from thresholds; identification and verification steps; collection and retention of beneficial ownership information; as well as exclusions and CTR […]
BENEFICIAL OWNERSHIP SURVEY RESULTS
On May 5, 2016 FinCEN issued its final rule on beneficial ownership and customer due diligence. This rule was issued to strengthen customer due diligence requirements for covered institutions. The rule included a new requirement to identify and verify the identities of beneficial owners of legal entity customers (LEC). A beneficial owner was deemed as any individual who owns 25 percent or more of the equity interests of a LEC and a single individual with […]