On March 6, 2020, the Financial Action Task Force (FATF) released guidance relating to digital ID systems. In their release, the FATF explains that an understanding of how digital ID systems work is essential to apply the risk-based approach recommended in this Guidance. Specifically, FATF said the following

On 3/6/2020, OFAC issued FAQ 828 as guidance relating to humanitarian assistance with regard to the Coronavirus Disease 2019 (COVID-19) outbreak in Iran.

On March 4, 2020, the Financial Crimes Enforcement Network (FinCEN) assessed a $450,000 civil money penalty against the former Chief Operational Risk Officer, Michael LaFontaine, at U.S. Bank for his failure to prevent BSA/AML violations during his time of employment. In their release, FinCEN explains that U.S. Bank used automated transaction monitoring software to spot potentially suspicious activity but improperly capped the number of alerts generated. In addition, FinCEN states that while under the former risk officer’s leadership, the bank failed to staff the BSA compliance function with enough people to review even the reduced number of alerts.

FinCEN explains that…

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.

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…

On November 12, 2019, FinCEN released an advisory on the FATF-identified jurisdictions with AML/CFT deficiencies.   This advisory, known as FIN-2019-A007, relays information to US financial institutions regarding countries the Financial Action Task Force (FATF) has identified as having deficiencies. 

On 11/8/19, FinCEN announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate.  The purchase amount threshold remains $300,000 for each covered metropolitan area, which includes…