Bank Secrecy Act
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What do you call your BSA Program? Moving from BSA to AML/CFT
Many examiners now use the term Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) instead of “BSA/AML” to reference this collection of laws and regulations, to align with the AML Act.
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A Trust Company & the Bank Secrecy Act: Is your BSA program good, or good enough?
While all aspects of the Bank Secrecy Act (BSA) rules may not be required for a trust company that are required for depository financial institutions, the oversight obligation and importance is not diminished. Trusts intrinsically have elevated risk based on the transparency of structure, ownership, and purpose. Section 352 of the USA PATRIOT Act requires […]
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Mail Theft and Fraud and SARs…“Oh My!” FinCEN Alert on Mail Theft and SAR Requirements
Have you heard that checks are a dying breed? The industry has been saying that longer than I have been in banking, and that more than half the time I have been alive, yet checks are still being negotiated! According to an article by the Federal Reserve Bank of Atlanta, while checks as a preferred […]
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FinCEN Alert on Sanctioned Russian Elites
In January 2023, the Financial Crimes Enforcement Network (FinCEN) published an alert, FIN-2023-Alert002, regarding potential investments in the United States commercial real estate (CRE) market by “sanctioned Russian elites and their proxies”. This Alert follows a similar Alert issued in March 2022, FIN-2022-Alert001. CRE, as mentioned in the Alert, can have highly complex ownership and […]
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BSA / OFAC Matters: New Sanctions Against Russia and Belarus
On May 8, 2022, by the United States, through the Office of Foreign Assets Control (OFAC), introduced new sanctions against Russia and Belarus . The new sanctions will take effect on June 7, 2022. Read on to learn more.
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Is your Financial Institution impacted by the BSA/AML Examination Updates?
Karen Leiter, Regulatory Compliance Director at CLA, summarizes the updates to BSA / AML for the first half of 2021. Read on to learn more and how CLA can help your financial institution.
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FinCEN Guidance and Advisory on Virtual Currencies
On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued both guidance and an advisory on virtual currencies
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OFAC Releases Framework for Compliance
On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued “A Framework for OFAC Compliance Commitments”.
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Federal Reserve Issues Enforcement Action for BSA Violations
On April 25, 2019, the Federal Reserve Board issued an enforcement action against Sumitomo Mitsui Banking Corporation, Tokyo, Japan (bank) for Bank Secrecy Act (BSA) violations.
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Money Transmitter Receives Civil Money Penalty for Failing to Register as MSB
On April 18, 2019, the Financial Crimes Enforcement Network (FinCEN) announced it assessed a civil money penalty against a peer-to-peer exchanger of convertible virtual currency for violating the Bank Secrecy Act (BSA).