On April 22, 2023, coinciding with the Earth Day celebration, FinCEN issued a press release to remind financial institutions to remain vigilant in identifying and reporting suspicious activity related to environmental crimes. According to FinCEN, environmental crimes frequently involve transnational criminal activity related to several of FinCEN’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) National Priorities, including corruption, fraud, human trafficking, and drug trafficking.

On April 15, 2024, FinCEN, in close coordination with the Department of State’s Diplomatic Security Service (DSS), issued a Notice to financial institutions on fraud schemes related to the use of counterfeit U.S. passport cards. The Notice provides an overview of typologies associated with U.S. passport card fraud, highlights select red flags to assist financial institutions in identifying and reporting suspicious activity, and reminds financial institutions of their reporting requirements under the BSA.

VIDEO: LE & CD Signature Requirements

In this Compliance Clip (video), Adam reviews the LE and CD signature requirements of Regulation Z. As you will see, Regulation Z provides a few options for applicant signatures, but also has a few requirements that must be met. A transcript of this video is now available.

On March 27, 2024, the CFPB issued a circular warning remittance transfer providers that false advertising about the cost or speed of sending a remittance transfer can violate federal law. The circular highlights several marketing practices relating to sending international money transfers that may violate the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices.

On March 29, 2024, FinCEN issued a notice and request for information and comment regarding the Customer Identification Program (CIP) Rule requirement for banks to collect a taxpayer identification number (TIN), among other information, from a customer who is a U.S. person, prior to opening an account. Specifically, FinCEN seeks information to understand the potential risks and benefits, as well as safeguards that could be established, if banks were permitted to collect partial SSN information directly from the customer for U.S. individuals and subsequently use reputable third-party sources to obtain the full SSN prior to account opening. 

On March 28, 2024, the FDIC issued the March 2024 edition of the Consumer Compliance Supervisory Highlights. The purpose of this publication is to enhance transparency regarding the FDIC’s consumer compliance supervisory activities and to provide a high-level overview of consumer compliance issues identified in 2023 through the FDIC’s supervision of state non-member banks and thrifts.