All in BSA

Over the last week, FinCEN updated their CTR Frequently Asked Question (FAQ) # 16 - for the third time in recent days. A few weeks ago, FinCEN started the process of changing how they want CTR filers to complete CTRs when a person has multiple “roles” in the transaction. Initially, FinCEN updated CTR FAQ 16 with a new answer, but then reverted to the original answer to FAQ 16 after apparent multiple calls from bankers questioning this change (that did not have an associated announcement or even changes to the CTR instructions). This week, we have received reports that FinCEN released a statement

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). Click this link to watch the video.

What is BSA?

Adam uses this Compliance Clip (video) to explain what BSA is in the banking industry. This video provides a high-level overview of BSA and money laundering, giving a general overview of the rule. For more information on BSA and anti-money laundering laws, take a look at our BSA Basics program at

The Financial Crimes Enforcement Network (FinCEN) recently (8/28/19) launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies rooted in FinCEN’s unique authorities under the Bank Secrecy Act (BSA) to combat illicit finance threats and related crimes, both domestically and internationally. According to the FinCEN release, GID will leverage FinCEN’s BSA authorities, including Section 311 of the USA PATRIOT Act, to investigate and target terrorist finance and money laundering threats, and GID will work more closely with foreign counterparts to coordinate actions against such threats when appropriate. FinCEN also states that GID will

On August 21, 2019, the Financial Crimes Enforcement Network (FinCEN) issued an advisory (FIN-2019-A006) to alert financial institutions to possible schemes related to the trafficking of fentanyl and other synthetic opioids.  FinCEN explains that this new advisory will assist financial institutions in detecting and reporting suspicious activity, ultimately making it harder and more costly for criminals to (i) commit crimes related to the trafficking of synthetic opioids; (ii) hide and use their illicit money; and (iii) continue fueling the opioid epidemic that is currently occurring in the United States. 

Fin-2019-A006 highlights the

On 8/19/19, the NCUA issued guidance for federally insured credit unions on how they can serve lawfully operating hemp businesses.  As the 2018 Farm Bill made a number of changes to how hemp is treated under federal law, some credit unions have lawfully operating hemp businesses within their fields of membership.  The NCUA explains that credit unions may provide the customary range of financial services for business accounts, including loans, to lawfully operating hemp related businesses within their fields of membership.

In the guidance, the NCUA explains that

On July 22, 2019, the joint agencies issued a statement to improve transparency of risk-focused BSA/AML supervision. The statement outlines common practices for assessing a bank's money laundering/terrorist financing risk profile, assisting examiners in scoping and planning the examination and initially evaluating the adequacy of the BSA/AML compliance program. Using this approach, the agencies generally are able to allocate more resources to higher-risk areas and fewer resources to lower-risk areas when conducting BSA/AML examinations. The statement does not establish new requirements, and also notes that having a risk-based compliance program enables a bank to allocate compliance resources commensurate with its risk.

4 Tips for Conducting BSA Training for Directors

In this Compliance Clip (video), Adam provides four tips that can be used when conducting BSA/AML training for directors of the Board. These tips are designed to help BSA/AML professionals craft a short, sweet, and sufficient training program for the board of directors.

For those interested in more information on providing Bank Secrecy Act training to the board of directors, be sure to check out our own BSA/AML Training for Directors in our at