More about Karen.Leiter@claconnect.com
Blog Posts by Karen.Leiter@claconnect.com:
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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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Regulation E: What Everyone is Talking About
Reg E is a very customer-centric regulation, and that concept does not appear to be changing anytime soon.
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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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1071 & What that means to your Financial Institution
Most financial institutions (FI) are aware of the current regulatory requirements to collect demographic information for applicants on certain covered transactions and soon similar demographic requirements will soon apply to small business applications. On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) issued the small business lending rule as final, which implements the small […]
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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.