On April 3, 2020, the Financial Crimes Enforcement Network (FinCEN) updated its guidance from March 16 regarding Bank Secrecy Act (BSA) reporting and COVID-19-related fraudulent transactions and scams. The update provides that institutions making Small Business Administration Paycheck Protection Program (PPP) loans will not be required to re-verify beneficial ownership for existing customers. FinCEN reminded financial institutions that BSA compliance obligations are still in place, and also introduced an online contact mechanism to communicate with FinCEN regarding BSA obligations during the COVID-19 pandemic.


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