Blog — Compliance Cohort

On February 6, 2024, National Credit Union Administration (NCUA) Chairman Todd M. Harper delivered a speech at the Brookings Institution, where he addressed the current key issues in the credit union industry. Chairman Harper’s remarks focused on the credit union performance, vendor authority, central liquidity facility, and consumer financial protection.

Feb 5
Feb 5 FinCEN Seeks Comments on the Renewal of CTR Requirements

On February 5, 2024, FinCEN issued a notice and request for comments regarding the renewal, without change, of existing information collection requirements relating to reports of transactions in currency. Under Bank Secrecy Act, financial institutions are required to report transactions in currency of more than $10,000 using FinCEN Form 112 or the Currency Transaction Report (CTR)

Feb 5
Feb 5 FinCEN Issues Alert on Israeli Extremist Settler Violence Against Palestinians

On February 1, 2024, FinCEN issued an alert related to the financing of Israeli extremist settler violence against Palestinians in the West Bank. The alert provides select red flags to assist U.S. financial institutions in identifying and reporting suspicious activity that finances such violence.

Feb 1
Feb 1 FinCEN Fines an AML Officer $100,000 for BSA Violations

On January 31, 2024, FinCEN assessed a $100,000 civil money penalty on Gyanendra Kumar Asre (Asre) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. In addition, FinCEN imposed a five-year ban on Asre’s participation in the conduct of the affairs of any financial institution subject to the BSA.

Feb 1
Feb 1 OCC Fines City National Bank $65 Million

On January 31, 2024, the OCC assessed a $65 million civil money penalty against City National Bank related to systemic deficiencies in the Bank’s risk management and internal controls. The agency also issued a cease-and-desist order requiring the bank to take broad and comprehensive corrective actions to improve its strategic plan, operational risk management, compliance risk management, strategic risk management, and investment management practices.

Jan 31
Jan 31 FinCEN Requests Comments for BOI Requests

On January 30, 2024, FinCEN issued a notice and request for comments on the proposed information collection associated with requests made to FinCEN, by certain persons, for beneficial ownership information, consistent with the requirements of the Beneficial Ownership Information Access and Safeguards final rule. The BOI Access Rule implements CTA's strict data protection rules for sensitive personal information sent to FinCEN.

Jan 30
Jan 30 FinCEN Proposes Rule and Identifies Al-Huda Bank as Primary Money Laundering Concern

On January 29, 2024, FinCEN issued a finding and notice of proposed rulemaking that identifies Al-Huda Bank, an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial institution of primary money laundering concern. Along with its finding, FinCEN proposed imposing a special measure that would sever the bank from the U.S. financial system by prohibiting domestic financial institutions and agencies from opening or maintaining a correspondent account for or on behalf of Al-Huda Bank.

Jan 25
Jan 25 CFPB Proposes Rule to Block Potential Source Junk Fees

On January 24, 2024, the CFPB proposed a new rule to block banks and other financial institutions from one potential source of new junk fee revenue. The proposed rule would prohibit non-sufficient funds (NSF) fees on transactions that financial institutions decline in real time such as declined debit card purchases and ATM withdrawals, as well as some declined peer-to-peer payments.

Jan 22
Jan 22 FRB Fines Foreign Bank for Unauthorized Disclosure of Supervisory Information