Written by Bernadette Clair, Regulatory Compliance Counsel
FinCEN Roundtable Discussion. FinCEN will hold a roundtable discussion on October 29, 2012, at the Los Angeles Branch of the Federal Reserve Bank of San Francisco, regarding the Advance Notice of Proposed Rulemaking (ANPR) on Customer Due Diligence (CDD) Requirements for Financial Institutions.
FinCEN seeks clarification primarily on issues dealing with beneficial ownership, risk mitigation, due diligence on trust accounts, and shell companies. See the notice for the complete list of issues, and information on attending the hearing – requests to attend the roundtable discussion must be submitted to FinCEN no later than October 19, 2012.
FinCEN previously held a public hearing regarding the ANPR on July 31st. A portion of the hearing is available via archived webcast, and a summary of the hearing is available here.
For more information on the ANPR itself, see our previous blogs on March 5th and March 6th.
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FinCEN Webinars. FinCEN recently held informational webinars on the new Suspicious Activity Report (SAR), Currency Transaction Report (CTR), and Designation of Exempt Person (DOEP) form. The webinars provided general information and guidance on filing the new reports.
Currently, credit unions have the option of submitting either the new reports or the legacy reports through the BSA E-Filing system. However, after March 31, 2013, use of the new reports will be mandatory and the legacy reports will be removed from the BSA E-Filing System.
FinCEN’s archived webinar on the new SAR is available for viewing here, and the accompanying presentation materials may be found here.
FinCEN’s archived webinar on the new CTR and DOEP is available for viewing here, and the accompanying presentation materials may be found here.
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BSA Blast. NAFCU Members, the October 2012 issue of the BSA Blast is available for download. This issue features articles on BSA E-filing and the HSBC case study and report issued by the United States Senate Homeland Security and Government Affairs Permanent Subcommittee on Investigations.
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