All in BSA

On November 13, 2024, FinCEN issued an alert to help financial institutions identify fraud schemes associated with the use of deepfake media created with generative artificial intelligence (GenAI) tools. The alert explains typologies associated with these schemes, provides red flag indicators to assist with identifying and reporting related suspicious activity, and reminds financial institutions of their reporting requirements under the Bank Secrecy Act.

On October 30, 2024, 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 last 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.

On October 23, 2024, FinCEN issued an alert to assist financial institutions in identifying and reporting suspicious activity supporting Lebanese Hizballah (Hizballah), a U.S.-designated Foreign Terrorist Organization. The alert builds upon the agency’s May 2024 advisory on Iran-backed terrorist organizations and offers a comprehensive overview of Hizballah’s global criminal financial networks.

VIDEO: Incorporating FinCEN Priorities into Risk Assessment

In this Compliance Clip, Adam discusses the importance of integrating FinCEN's national priorities into financial institutions' BSA/AML/CFT risk assessments, highlighting recent proposals from FinCEN and regulatory agencies aimed at updating compliance requirements. Adam provides ways on how financial institutions can proactively incorporate these priorities into their risk assessments. A transcript of this video is now available.

On October 10, 2024, the OCC announced a cease and desist order and a $450 million civil money penalty against TD Bank, N.A. and TD Bank USA, N.A., for deficiencies in the bank’s BSA and AML compliance program. The OCC determined that the bank failed to develop and maintain a BSA/AML program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations.