Written by Shari R. Pogach, Regulatory Paralegal
The Financial Crimes Enforcement Network (FinCEN) recently issued revised Geographic Targeting Orders (GTO) to target shell companies buying luxury properties. Transactions conducted in Honolulu, Hawaii, are now included under the revised GTO, making a total of seven major metro areas where U.S. title insurance companies are required to identify the natural persons behind shell companies used to pay for high-end real estate. The August 22, 2017, revised GTO also has broadened the transaction categories to now include wire transfers. Any covered transaction made "without a bank loan or other similar form of external financing; and ... made, at least in part, using currency or a cashier’s check, a certified check, a traveler’s check, a personal check, a business check, or a money order in any form, or a funds transfer" must be reported to FinCEN.
In addition to the revised GTO, FinCEN released FIN-2017-A003 to provide financial institutions and the real estate industry with information on the money laundering risks associated with some real estate transactions. The guidance provides some red flag activity and case examples. FinCEN also has a frequently asked questions document here.
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FFIEC BSA/AML Examination Manual Update. Word on the street is that an interagency group of federal banking regulators has started working on amending the Federal Financial Institutions Examination Council’s Bank Secrecy Act exam manual to account for the new customer due-diligence rule issued by the Financial Crimes Enforcement Network last year. No details as yet on how in depth the updated manual and standalone sections on the Customer Due-Diligence Rule will address the extent to which financial institutions will have to obtain and verify beneficial ownership data from existing clients or which of the rule's provisions will be prioritized for enforcement.
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Useful Tools. Our credit union industry friend, Andy Keeney, of Kaufman & Canoles, has provided you with these two useful resource tools: NCUA's List of Required Policies for Board of Directors of Credit Unions and Credit Union Board Compensation by State.
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Upcoming NAFCU Webcasts.
CUSO Rules and RegulationsWednesday, September 6 | 2:00 p.m. – 3:30 p.m. ET
BSA/AML Risk Assessment: Building a Program to Evaluate Risk and Ensure ComplianceTuesday, September 12 | 2:00 p.m. – 3:30 p.m. ET
Vendor Management TrainingWednesday, September 13 | 2:00 p.m. – 3:30 p.m. ET
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A Final Laugh. Here, courtesy of Payments.com are a few quick stories of some incompetent bank robbers to hopefully give you a chuckle, because we all just need a laugh once in a while.
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