Proposed Changes to the BSA Travel Rule

The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board have asked for comments on a proposed rule that would amend the recordkeeping and travel rule regulations under the Bank Secrecy Act. FinCEN and the Board, pursuant to their shared authority, are proposing amendments to the recordkeeping rule jointly, while FinCEN, pursuant to its sole authority, is proposing amendments … Read More

The Pandemic and the Compliance Department—Social Distancing Means Changing Risks

With the rampant fraud associated with the pandemic, the institution’s compliance staff may be considered the unsung heroes of the institution.  Along with protecting the institution from steep fines and regulatory violations, the Bank Secrecy Act (BSA) staff protect the institution and customers by identifying and stopping illicit activity. Even with the stay at home orders, these responsibilities continue. With … Read More

Beneficial Owner Verification Requirements

FinCEN released a Final Rule under the Bank Secrecy Act, which imposes specific requirements for financial institutions to identify and verify the identity of beneficial owners of legal entity customers when opening a new account. Beneficial owner – is either an individual who directly or indirectly owns 25 percent or more of the equity interest of a legal entity customer, … Read More

BSA Violations

FinCEN’s penalty assessment against Gibraltar Private Bank reads like a Stephen King novel for BSA compliance officers. The ongoing deficiencies and either the willful blindness or ignorance by Gibraltar caused me heartburn just reading the assessment report. Gilbraltar’s issues have been ongoing since at least 2010, when the OCC first warned Gibraltar of its BSA deficiencies. A Consent order was … Read More

More BSA on the way?

In January, the Government Accountability Office released a report, in response to Congress’ request, titled Internal Remittances – Money Laundering Risks and Views on Enhanced Customer Verification and Recordkeeping Requirements. This was initiated from a 2015 Senate bill, the Remittance Status Verification Act of 2015.  While the Act did not proceed further, it would have required remittance transfer providers (including credit unions) to, before … Read More