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All in 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 www.compliancecohort.com/bsa-basics.
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.
On July 17, 2019, the CFPB issued an updated advisory to financial institutions encouraging them to work with law enforcement agencies “whenever they suspect that an older adult is the target or victim of financial exploitation.” In their advisory, the CFPB also recommended that financial institutions file SARs - which FinCEN has already provided guidance on.
On July 12, 2019, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT deficiencies. This advisory, known as FIN-2019-A004, relays information to US financial institutions regarding countries the Financial Action Task Force (FATF) has identified as having deficiencies.
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 https://www.compliancecohort.com/bsa-training-for-directors.
On May 2, 2019, OFAC released a document titled A Framework for OFAC Compliance Commitments in order to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with a framework on the essential components of a sanctions compliance program. The document also…
