On July 8, 2024, FinCEN issued another set of updates to its Beneficial Ownership Information Frequently Asked Questions. The FAQs are prepared by the agency in response to inquiries received relating to the BOI Reporting Rule and BOI Access and Safeguards Rule.

Jul 9
Jul 9 FinCEN Issues Alert on Fraudulent Scams that Target BOI Reporting Entities

Adam Witmer

Regulatory Update, BSA

In early July, FinCEN published an alert on the Beneficial Ownership Information webpage to warn of fraudulent attempts to solicit information from individuals and entities who may be subject to reporting requirements under the Corporate Transparency Act.

Jul 8
Jul 8 FATF Updates List of Deficient Countries

Adam Witmer

BSA, Regulatory Update

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.

Jul 3
Jul 3 CFPB Releases Summer 2024 Edition of Supervisory Highlights

Adam Witmer

Regulatory Update

On July 2, 2024, the CFPB released the Summer 2024 Edition of its Supervisory Highlights that notes recent supervisory findings in auto and student loan servicing companies, debt collectors, and other financial services providers. The findings included in the report cover examinations in the areas of auto and student loan servicing and debt collection, including credit card debt collections, as well as credit card account management with a focus on medical credit cards that were completed from April 1, 2023 to December 31, 2023.

Jul 3
Jul 3 FRB Fines Silvergate for AML Monitoring Deficiencies

Adam Witmer

BSA, Regulatory Update

On July 1, 2024, the Federal Reserve Board fined Silvergate Capital Corporation and Silvergate Bank $43 million for deficiencies in Silvergate's monitoring of transactions in compliance with anti-money laundering laws. In May 2023, Silvergate announced that it was voluntarily winding down its operations, and has now paid back all deposits to its customers.

Jul 1
Jul 1 FinCEN Proposes Rule to Strengthen and Modernize AML/CFT Programs

Adam Witmer

Regulatory Update, BSA

On June 28, 2024, FinCEN announced a proposed rule to strengthen and modernize financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs. According to FinCEN, the proposed rule would amend the existing regulations to explicitly require that AML/CFT programs be effective, risk-based, and reasonably designed.

Jul 1
Jul 1 CFPB’s 2023 Fair Lending Report to Congress

Adam Witmer

Regulatory Update, Fair Lending

On June 26, 2024, the CFPB released its Fair Lending Annual Report to Congress, describing the Bureau’s fair lending activities in enforcement, guidance and rulemaking, interagency coordination, and outreach and activities for calendar year 2023. Specifically. The Fair Lending Annual Report to Congress fulfills the Bureau’s statutory responsibility to report annually to Congress on public enforcement actions taken under the ECOA as well as the utility of the HMDA’s mortgage loan data collection requirements.

Jun 27
Jun 27 FinCEN Issues Final Rule to Sever Al-Huda Bank from the US Financial System

Adam Witmer

Regulatory Update, BSA

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.

Jun 26
Jun 26 CFPB Extends Small Business Lending Rule Compliance Dates

Adam Witmer

Regulatory Update

On June 25, 2024, the CFPB issued an interim final rule to extend compliance deadlines for the small business lending rule. This is after a federal court in Texas required the CFPB to extend the rule’s compliance deadlines to compensate for the period stayed pending the Supreme Court’s decision in CFPB v. CFSA.

Jun 24
Jun 24 FinCEN Issues Supplemental Advisory on Fentanyl

Adam Witmer

Regulatory Update

On June 20, 2024, FinCEN issued an advisory to alert U.S. financial institutions to new trends in the illicit fentanyl supply chain and urge vigilance in identifying and reporting suspicious activity associated with Mexico-based transnational criminal organizations and their illicit procurement of fentanyl precursor chemicals and manufacturing equipment from People’s Republic of China-based suppliers. The advisory is supplementary to the 2019 Advisory on Illicit Financial Schemes and Methods Related to the Trafficking of Fentanyl and Other Synthetic Opioids.

Jul 9
Jul 9 FinCEN Updates the BOI FAQs

Jul 9
Jul 9 FinCEN Issues Alert on Fraudulent Scams that Target BOI Reporting Entities

Jul 8
Jul 8 FATF Updates List of Deficient Countries

Jul 3
Jul 3 CFPB Releases Summer 2024 Edition of Supervisory Highlights

Jul 3
Jul 3 FRB Fines Silvergate for AML Monitoring Deficiencies

Jul 1
Jul 1 FinCEN Proposes Rule to Strengthen and Modernize AML/CFT Programs

Jul 1
Jul 1 CFPB’s 2023 Fair Lending Report to Congress

Jun 27
Jun 27 FinCEN Issues Final Rule to Sever Al-Huda Bank from the US Financial System

Jun 26
Jun 26 CFPB Extends Small Business Lending Rule Compliance Dates

Jun 24
Jun 24 FinCEN Issues Supplemental Advisory on Fentanyl

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