All in BSA

On July 19, 2024, the OCC, the Federal Reserve Board, the FDIC, and the NCUA issued a notice of proposed rulemaking to to update their requirements for supervised institutions to establish, implement, and maintain effective, risk-based, and reasonably designed anti-money laundering and countering the financing of terrorism (AML/CFT) programs. According to the FDIC’s press release, the amendments are intended to align with changes concurrently proposed by the U.S. Department of the Treasury’s FinCEN.

On July 16, 2024, FinCEN, OFAC, and the FBI issued a joint Notice to financial institutions urging them to be vigilant in detecting, identifying, and reporting timeshare fraud perpetrated by Mexico-based transnational criminal organizations. The Notice provides methodologies, typologies, and red flag indicators to help financial institutions identify potential timeshare fraud in their transactions.

On July 11, 2024, FinCEN issued a supplemental alert to highlight additional red flags regarding financing of Israeli extremist settler violence against Palestinians in the West Bank. In February 2024, FinCEN  issued an alert to financial institutions related to funding of terrorist attacks against Palestinians in the West Bank by Israeli extremists.

On July 3, 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 June 26, 2024, FinCEN issued a final rule under the USA PATRIOT Act Section 311 that severs Al-Huda Bank from the United States financial system by prohibiting domestic financial institutions and agencies from opening or maintaining a correspondent account for or on behalf of Al-Huda Bank, an Iraqi bank that serves as a conduit for terrorist financing. Al-Huda Bank is a foreign financial institution based in Iraq found to be of primary money laundering concern.