BSA ALERT! Update to CTR FAQ 16?
In this Compliance Clip (video) Adam talks about a whirlwind in the BSA world that took place over the last few weeks. FinCEN apparently made an update to CTR FAQ 16 (without any notification or clarification) that would change how CTRs are reported when a person conducting a transaction has multiple “roles,” such as would be the case if an individual made deposits on both their personal account and the account for a business. Adam explains what happened with FAQ 16 and what we need to look for going forward. For those who enjoy a bit of excitement in the BSA world, the change to FAQ 16 has definitely given something to think about (and to share with your BSA officer if they aren’t aware of this).
CLARIFICATION: As we state in this video, FinCEN removed the new answer to FAQ 16 that was temporarily available on their website, so the current guidance on how to report CTRs for an individual who has multiple roles appears to be the same as it always has been. However, CTR filers should watch for future changes as the whirlwind this week seems to be an insight of what may happen in the future. As you would expect, future regulatory changes like this will be covered in our Quarterly Compliance Update program, if and when the change occurs. Questions regarding the change that was removed should be addressed to FinCEN.