Archive

SAR- E-FILING SYSTEM CHANGES

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 […]

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 […]

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 […]

SAR CHANGES

The Financial Crimes Enforcement Network (FinCEN) announced changes to the Suspicious Activity Reports Electronic Data Fields on February 2, 2017. On January 26, 2018 FinCEN issued an Important Notice to E-Filers that announces an update to the Suspicious Activity Report (SAR). The 2018 announcement states, ” the FinCEN Suspicious Activity Report (SAR) available on the BSA E-Filing System will be updated to adhere to the changes defined in Federal Register notice posted on February 2nd, […]