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This manual highlights the ever-increasing federal expectations for BSA. Customer/Member Due Diligence remains the focus in BSA compliance, with the major emphasis on Suspicious Activity Reporting. The voluminous changes coming out of AMLA 2020 and the Corporate Transparency Act will be detailed. The latest guidelines on the National Strategy on Countering Corruption, COVID-Fraud, Environmental Crime, Ransomware, Online Child Sexual Exploitation (OCSE), and Antiquities and Art are covered. Ongoing monitoring, and due diligence expectations for Hemp-Related / Marijuana-Related Enterprises (HRE/MRE), Money Services Businesses (MSB), Third-Party Payment Processors (TPPP), and other “High-Risk” Clients are highlighted. Institutional risk assessments, and the latest guidance on high-risk products and services, convertible virtual currencies (CVCs), cyber events and cyber-related crime, human trafficking and human smuggling, elder and vulnerable adult exploitation, and other fraud schemes are reviewed.
Suspicious activity reporting and the most recent guidance from Treasury on proper Suspicious Activity Report completion are discussed. The impacts to financial institutions from the currently being updated federal BSA examination procedures are identified. The regulations affecting financial institutions from the Office of Foreign Asset Control (OFAC) are highlighted and the Sanctions Compliance Program (SCP) framework is discussed. Suspicious transactions, terrorist financing, and other money laundering techniques are also reviewed.
Currency Transaction Reporting (CTR), Exemptions from CTR reporting, Customer/Member Identification (CIP) requirements, foreign correspondent banking and private banking account management, SAR reporting requirements for insurance affiliates, record retention requirements, and the evolution of BSA are documented in detail.
- Anti-Money Laundering Act (AMLA) 2020 and Corporate Transparency Act Implementations
- Beneficial Ownership Modifications
- Customer/Member Due Diligence
- Suspicious Activity Reporting (SAR) – Latest Trends and Rulings
- Money Services Businesses (MSB), Third-Party Payment Processors (TPPP), Hemp and Marijuana Related Enterprises (HRE/MRE), Convertible Virtual Currencies (CVC), and Other “High-Risk” Clients
- Pandemic-related Fraud Schemes
- Risk Assessments
- Examination Procedures – Latest Updates
- OFAC Compliance – Sanctions Compliance Program (SCP)
- Money Laundering Techniques and Suspicious Transactions
- Currency Transaction Reporting
- CTR Exemption Opportunities
- Customer/Member Identification (CIP)
- Foreign Correspondent Bank and Private Banking EDD
- SAR for Insurance Affiliates
- Record Retention Requirements
- Information Sources
- BSA ” Evolution” and “Lessons” from BSA Enforcement Actions
The Treasury Department continues to rely on financial institutions to serve as the “front-line gatekeepers” for law enforcement efforts to safeguard the U.S. financial system from the abuses of financial crimes, including money laundering and terrorist financing. The federal regulatory agencies continue to rely on financial institutions to take “every reasonable step” to identify, minimize, and manage any risks that illicit financial activity may pose to the individual institution and to the industry. Ongoing initiatives by the Financial Crimes Enforcement Network (FinCEN) and the continued expansions in the federal examination procedures reinforce the need to have a strong BSA program at your institution. This manual covers the major issues and opportunities in the ever-expanding environment of the Bank Secrecy Act.