All in BSA

FinCEN Provides Guidance on Convertible Virtual Securities

Adam Witmer
Regulatory Update, BSA

On May 9, 2019, FinCEN issued two different pieces of guidance relating to virtual currency.  The first issuance is guidance titled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies,” also known as FIN-2019-G001.  The second issuance was an Advisory (FIN-2019-A003) on Illicit Activity Involving Convertible Virtual Currency.  

CFPB Issues Analysis on Elder Financial Exploitation

Adam Witmer
BSA, Regulatory Update

On February 27, 2019, the CFPB issued a report titled “Suspicious Activity Reports on Elder Financial Exploitation: Issues and Trends.”  In their release, they explain that financial institutions have reported over 180,000 suspicious activities targeting older adults. Combined, these Suspicious Activity Reports (SARs) involved more than $6 billion in elder financial exploitation.

The first of its kind, this report presents a public analysis of SARs filed for elder financial exploitation between 2013 and 2017.  The CFPB explains that the findings in the analysis provide an “opportunity to better understand the complex problem of elder financial exploitation and to identify ways to improve prevention and response.” The full report runs 35 pages long and includes several sections including…

Money Laundering 101

Money Laundering 101

Adam Witmer
BSA

In this Compliance Clip (video), Adam provides an overview of money laundering and gives a big picture illustration of how it applies to financial institutions. This foundational explanation of money laundering gives a great practical example of how money laundering can occur and discusses the three steps illicit “actors” use to launder money in the US financial system. This clip would be a great training resource for anyone who is new to BSA to help them understand what money laundering is. In fact, Adam took these slides directly from our BSA Bootcamp, which is a 3 1/2 hour video webinar that provides a foundational overview of all BSA rules and regulations. For more foundational BSA training just like this, our BSA Bootcamp is available in our store here: www.compliancecohort.com/video-webinar-bsa-bootcamp

Back-Up BSA Officer Training Expectations

Adam Witmer
BSA

Bank Secrecy Act rules and regulations are complex, challenging, and at times, overwhelming.  Not only must a BSA/AML professional be able to complete daily tasks like reviewing transactions and filing reports, but they also must be a knowledge expert in the many areas of the Bank Secrecy Act.  For this reason, many financial institutions employ professionals who specialize in the Bank Secrecy Act and anti-money laundering rules and regulations.

But what happens when this specialist leaves the financial institution?

Unfortunately, financial institutions sometimes find themselves in a difficult situation when a BSA professional gets promoted or leaves their organization.  This is where having continuity in BSA/AML knowledge in a financial institution is important. In fact, the FFIEC BSA Exam manual states that a BSA program should have continuity despite changes in employees.  In order to do this, cross-training of employees in BSA & AML rules is essential.

FinCEN Issues Statement to Cultivate BSA/AML Innovation

Adam Witmer
BSA, Regulatory Update

On December 3, 2018 FinCEN and the joint agencies released an advisory to encourage and support the implementation of responsible innovation and new technology in the financial system.  The advisory encourages banks and credit unions to take innovative approaches to their Bank Secrecy Act (BSA) programs for combating money laundering, terrorist financing, and other illicit financial threats.  

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