All in BSA

FinCEN to Update CTR Reporting

Adam Witmer
BSA, Regulatory Update

On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a ruling relating to filing Currency Transaction Reports (CTRs) for sole proprietorships and legal entities operating under a “Doing Business As” (DBA) name. This short two-page ruling outlines how CTRs should be filed, starting on April 6, 2020 (and September 1, 2020 for batch filers). Unfortunately, this guidance is not clear and concise and actually seems to complicate things, so BSA Officers should take a close look at it. As you might expect, this topic will be included in our next Quarterly Compliance Update planned for April 2020.

CTRs with Multiple Transactions

CTRs with Multiple Transactions

Adam Witmer
BSA

In this Compliance Clip (video), Adam discusses some recent changes to CTR reporting. Specifically, FinCEN has updated its user guide in regards to reporting CTRs with multiple transactions. The guidance has flip-flopped a bit over the last few months, so you won’t want to miss this video.

What is Money Laundering?

Adam Witmer
BSA

In this Compliance Clip (video), Adam provides a simple explanation of money laundering. As BSA and AML rules can often be difficult to explain, this video provides a quick overview of money laundering in simple and easy to understand language.

Agencies Issue Hemp Guidance

Adam Witmer
BSA, Regulatory Update

On 12/3/2019, four regulators (FDIC, Federal Reserve, OCC, and FinCEN) issued a joint statement to clarify requirements for providing financial services to hemp-related businesses. The statement, which runs only three pages long and has about as many footnotes as it does content, emphasizes that banks are no longer required to file SARs for customers solely because they are engaged in the growth or cultivation of hemp in accordance with applicable laws and regulations.  Similar to recent NCUA hemp guidance, it is important to note that this guidance seems to…

USDA Issues HEMP Guidance

Adam Witmer
Regulatory Update, BSA

On 10/29/19, the USDA released a long-awaited interim final rule relating to the growing of industrial hemp. This program, as required by the 2018 Farm Bill, will establish a consistent regulatory framework around hemp production throughout the United States. As explained in their release, the USDA rule includes provisions for…

FinCEN Updates CTR FAQ 16 - Again...

Adam Witmer
BSA, Regulatory Update

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?

BSA ALERT! Update to CTR FAQ 16?

Adam Witmer
BSA, Regulatory Update

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.

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