By: Kyle Davis CRCM, CAMS

FinCEN finally issued the long-awaited FAQs concerning the upcoming Beneficial Ownership and customer due diligence rule. The FAQs address multiple implementation questions posed by the industry following the release of the final rule and first set of FAQs.  Important highlights include clarification on requirements when a business is identified as a beneficial owner (FAQ 3),  using previously gathered CIP information for verifying beneficial owners (FAQ 7), and what is required when a CD rolls over or a loan is renewed (FAQ 12).   It is highly recommended that institutions review the FAQs as soon as possible as implementation and training changes will be required prior to the May 11, 2018 required compliance date.  The FAQs can be found here.  ​

By: Kyle Davis CRCM, CAMS

On January 26, 2018,  FinCEN finalized several proposed updates to the Suspicious Activity Report (SAR).  FinCEN anticipates that the new SAR will be available for discrete filers in June 2018.  Batch filing institutions will be required to submit the updated SAR data in an XML based file, rather than the current ASCII based fixed-length delimited file. However, the BSA E-Filing System will continue to accept ASCII based batch files until January 1st, 2019. Batch filers will have six months from the go-live date in June to adhere to the new XML specification. To see a detailed listing of the changes, click here to see FinCEN's announcement.