On May 13, 2022, the U.S. Department of the Treasury issued its 2022 National Strategy for Combatting Terrorist and Other Illicit Financing, which identifies measures to increase transparency in the U.S. financial system and strengthen the AML/CFT framework. The 2022 Strategy addresses the key risks from the 2022 National Money Laundering, Terrorist Financing, and Proliferation Financing risk assessments and reflects the challenges posed by a world impacted by the Covid-19 pandemic, the increasing digitization of financial services, and increasing levels of corruption and fraud.

FinCEN has updated its “SAR Filings by Industry” webpage to include data from 2021. In addition to this webpage, FinCEN has an interactive map and and Interactive SAR Stats which allow BSA professionals to analyze what types of suspicious activity are being reported in their areas. As this data allows specific sorting of the data, BSA professionals are able to sort by many different fields including primary regulator, county, etc.

On March 17, 2022, FinCEN announced that it has assessed a $140 million civil money penalty against USAA Federal Savings Bank (USAA FSB) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. This is after FinCEN conducted a civil enforcement investigation and determined that grounds exist to impose a Civil Money Penalty against USAA FSB for violations of the BSA. According to the FinCEN’s press release, USAA FSB admitted that it willfully failed to implement and maintain an anti‑money laundering (AML) program that met the minimum requirements of the BSA from at least January 2016 through April 2021.

On March 10, 2022, FinCEN issued a press release to inform U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has issued public statements updating its lists of jurisdictions with strategic AML/CFT/CPF deficiencies following its plenary meeting this month. U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.

In early February, 2022, the Federal Reserve released a Synthetic Identity Fraud Mitigation Toolkit which offers a wide variety of informative resources for financial institutions, consumers and businesses on fraud mitigation. The issuance of the fraud mitigation toolkit is the next step in the Federal Reserve’s years-long commitment and engagement with fraud experts to support the payments industry in its battle against fraud.

On 1/24/2022, the FinCEN issued a Notice of Proposed Rulemaking (NPRM) that proposes and solicits public comment on the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs), in accordance with Section 6212 of the Anti-Money Laundering Act of 2020. In the pilot program, a financial institution with a SAR reporting obligation would be permitted to share SARs and information related to SARs with foreign branches, subsidiaries, and affiliates for the purpose of combating illicit finance risks, provided FinCEN approves and approves the conditions.

On 12/20/21, FinCEN released a Financial Threat Analysis on wildlife trafficking threat patterns and trend information identified in Bank Secrecy Act (BSA) data filed between January 2018 and October 2021. The result of the analysis shows that wildlife trafficking-related SARs filed between January 2018 and October 2021 trended significantly up and SARs filed in 2021 are on track to meet or exceed the amount of SARs filed in 2020 based on current trends.