All in BSA

On January 13, 2023, FinCEN issued an alert which aims to better aid financial institutions in the detection of financial activity related to human smuggling along the southwest border of the United States. The alert provides trends and typologies specifically related to human smuggling occurring along the SW border. It also provides red flag indicators to help financial institutions better identify transactions potentially related to human smuggling and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations.

On November 30, 2022, the FATF released its first ever report on money laundering from fentanyl and synthetic opioids with recommendations for countering financial flows from the illicit drug trade, which claims thousands of lives around the world. The report, which was co-led by the United States and Canada, looks at the way proceeds are laundered from synthetic opioids trafficking.

On November 1, 2022, FinCEN issued its most recent Financial Trend Analysis of ransomware-related Bank Secrecy Act (BSA) filings for 2021, indicating that ransomware continued to pose a significant threat to U.S. critical infrastructure sectors, businesses, and the public. FinCEN’s report focuses on ransomware trends in BSA filings from July-December 2021, and addresses the extent to which a substantial number of ransomware attacks appear to be connected to actors in Russia.

On October 31, 2022, 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 this 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.

VIDEO: BSA Changing to AML CFT?

In this Compliance Clip (video), Adam answers the question “Is BSA changing to AML/CFT and do we need to make changes to our BSA department names and titles?” Adam clarifies the origin of the term CFT and what financial institutions should really be focusing on in terms of BSA. A transcript of this video is now available.