Last week FinCEN held it’s annual Law Enforcement Awards Program ,which recognizes cases that have been successfully prosecuted using reports provided financial institutions, and emphasized how BSA reporting really does make a difference. The stories are always interesting but I think they also serve as a reminder to our teams that the work they do is important and has a real impact. And for many, this might be a much-needed reminder. Often, there is no […]
Tag: BSA
FINCEN ISSUES AN ANPRM FOR BSA RULES FOR REAL ESTATE TRANSACTIONS
On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) published an Advance Notice of Proposed Rulemaking (“ANPRM”) to solicit public comment on a potential rule to address the vulnerability of the U.S. real estate market to money laundering and other illicit activity. FinCEN said the systemic money laundering vulnerabilities presented by the U.S. real estate sector, and consequently, the ability of illicit actors to launder criminal proceeds through the purchase of real estate, threatens U.S. national […]
FINCEN ISSUES ANPRM ON BENEFICIAL OWNERSHIP REPORTING
On April 1, 2021, FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) requesting comments on new beneficial ownership reporting provisions included in the Corporate Transparency Act/Anti-Money Laundering Act of 2020, which was passed into law as part of the National Defense Authorization Act of 2021 on January 1, 2021. The ANPRM, published in the Federal Register on April 5, 2021, is requesting input on procedures and standards for reporting companies to submit information to […]
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 […]
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 […]