On February 23, 2024, FinCEN issued a notice and request for comments on the proposed renewal, without change, of an existing information collection relating to records of certain domestic transactions, commonly referred to as geographic targeting orders (GTOs). The information required to be recorded and reported pursuant to a GTO is basic information that a domestic financial institution or domestic nonfinancial trade or business would have access to in the normal course of doing business, such as payment, receipt, or transfer of funds information.

On February 22, 2024, FinCEN announced that Director Andrea Gacki traveled to Puerto Rico from February 20-22 to attend the 20th Annual Puerto Rico Bankers Association Symposium of Anti-Money Laundering and to meet with Puerto Rican officials to discuss illicit finance threats. Gacki’s engagement with Puerto Rican financial institutions and officials highlights FinCEN’s collaborative efforts to combat public corruption, fraud, and drug trafficking.

VIDEO: TRID Application

In this Compliance Clip (video), Adam talks about the six pieces of information r needed for a TRID application under Regulation Z. Adam discusses what constitutes a completed application and when the six pieces of information triggers the loan estimate requirements. A transcript of this video is now available.

On February 16, 2024, the CFPB revealed, through Terms of Credit Card Plans survey, that large banks are offering higher credit card terms and interest rates than small banks and credit unions, regardless of credit risk. The CFPB found that the 25 largest credit card issuers charged customers interest rates of 8 to 10 points higher than small- and medium-sized banks and credit unions, which can translate to $400 to $500 in additional annual interest for the average cardholder.

In February 2024, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements intended to help small entities comply with the Beneficial Ownership Information Access and Safeguards Rule. The Compliance Guide provides an overview of the Beneficial Ownership Information Access and Safeguards Rule requirements for small entities that obtain BOI from FinCEN.

On February 13, 2024, FinCEN issued a proposed rule to keep criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers.  The proposed rule aims to include certain investment advisers in the definition of “financial institution” under the BSA, prescribe minimum standards for anti-money laundering/countering the financing of terrorism (AML/CFT) programs to be established by covered investment advisers, require covered investment advisers to report suspicious activity to FinCEN pursuant to the BSA, and make several other related changes to FinCEN regulations. 

On February 13, 2024, FinCEN issued a Financial Trend Analysis (FTA)  reflecting an increase in BSA reporting associated with the use of convertible virtual currency (CVC) and online child sexual exploitation (OCSE) and human trafficking, covering the period from January 2020 to December 2021. According to FinCEN, they received a total of 2,311 BSA reports referencing CVC in connection with OCSE and human trafficking, totaling over $412 million in reported suspicious activity.

On February 12, 2024, the FFIEC on behalf of its member entities, issued a statement related to valuation discrimination and bias for member entities to consider in their consumer compliance and safety and soundness examinations. The statement provides principles for the examination of supervised institutions’ residential property appraisal and evaluation (valuation) practices to mitigate risks that may arise due to potential discrimination or bias in those practices, and to promote credible valuations.