All in BSA

What is Money Laundering?

Adam Witmer
BSA

In this Compliance Clip (video), Adam provides a simple explanation of money laundering. As BSA and AML rules can often be difficult to explain, this video provides a quick overview of money laundering in simple and easy to understand language.

Agencies Issue Hemp Guidance

Adam Witmer
BSA, Regulatory Update

On 12/3/2019, four regulators (FDIC, Federal Reserve, OCC, and FinCEN) issued a joint statement to clarify requirements for providing financial services to hemp-related businesses. The statement, which runs only three pages long and has about as many footnotes as it does content, emphasizes that banks are no longer required to file SARs for customers solely because they are engaged in the growth or cultivation of hemp in accordance with applicable laws and regulations.  Similar to recent NCUA hemp guidance, it is important to note that this guidance seems to…

USDA Issues HEMP Guidance

Adam Witmer
Regulatory Update, BSA

On 10/29/19, the USDA released a long-awaited interim final rule relating to the growing of industrial hemp. This program, as required by the 2018 Farm Bill, will establish a consistent regulatory framework around hemp production throughout the United States. As explained in their release, the USDA rule includes provisions for…

FinCEN Updates CTR FAQ 16 - Again...

Adam Witmer
BSA, Regulatory Update

Over the last week, FinCEN updated their CTR Frequently Asked Question (FAQ) # 16 - for the third time in recent days. A few weeks ago, FinCEN started the process of changing how they want CTR filers to complete CTRs when a person has multiple “roles” in the transaction. Initially, FinCEN updated CTR FAQ 16 with a new answer, but then reverted to the original answer to FAQ 16 after apparent multiple calls from bankers questioning this change (that did not have an associated announcement or even changes to the CTR instructions). This week, we have received reports that FinCEN released a statement

BSA ALERT! Update to CTR FAQ 16?

BSA ALERT! Update to CTR FAQ 16?

Adam Witmer
BSA, Regulatory Update

In this Compliance Clip (video) Adam talks about a whirlwind in the BSA world that took place over the last few weeks. FinCEN apparently made an update to CTR FAQ 16 (without any notification or clarification) that would change how CTRs are reported when a person conducting a transaction has multiple “roles,” such as would be the case if an individual made deposits on both their personal account and the account for a business. Adam explains what happened with FAQ 16 and what we need to look for going forward. For those who enjoy a bit of excitement in the BSA world, the change to FAQ 16 has definitely given something to think about (and to share with your BSA officer if they aren’t aware of this). Click this link to watch the video.

What is BSA?

What is BSA?

Adam Witmer
BSA

Adam uses this Compliance Clip (video) to explain what BSA is in the banking industry. This video provides a high-level overview of BSA and money laundering, giving a general overview of the rule. For more information on BSA and anti-money laundering laws, take a look at our BSA Basics program at www.compliancecohort.com/bsa-basics.

FinCEN Launches New Division

Adam Witmer
BSA, Regulatory Update

The Financial Crimes Enforcement Network (FinCEN) recently (8/28/19) launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies rooted in FinCEN’s unique authorities under the Bank Secrecy Act (BSA) to combat illicit finance threats and related crimes, both domestically and internationally. According to the FinCEN release, GID will leverage FinCEN’s BSA authorities, including Section 311 of the USA PATRIOT Act, to investigate and target terrorist finance and money laundering threats, and GID will work more closely with foreign counterparts to coordinate actions against such threats when appropriate. FinCEN also states that GID will

Load More