Bank Secrecy Act FinCEN

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
News & Analysis as of

2016 Year in Review: Money Laundering (Part One)

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

Cyber$ecurity: Recent Developments in the Protection of Financial Data

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Cyber$ecurity: Recent Developments in the Protection of Financial Data

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Western Union to Pay $586 Million in Restitution and Civil Penalties for AML Compliance Failure

On January 19, 2017, Western Union Financial Services, Inc. agreed to pay civil penalties and restitution to victims of fraud totaling $586 million to resolve actions brought by the U.S. Treasury Department’s Financial Crimes...more

Banking Problems for a Whole Industry

About half of the States have legalized marijuana for either or both medical and recreational use. Despite being legal under various state laws, businesses operating in the marijuana industry continue to encounter federal...more

Paying for the Wall: Will President Trump’s Administration Scrutinize, Tax, or Seize Remittances?

One of the most significant post-election questions for the financial-services industry—particularly global financial institutions that move money across borders—is what is the status of President-elect Trump’s proposal to...more

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

Financial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance. FinCEN began 2017 by...more

State Ballot Wins Only Amplify Questions About Pot Banking

The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...more

Nutter Bank Report, November 2016

Massachusetts Voters Approve Legalization of Marijuana for Recreational Purposes - Massachusetts voters have approved a ballot initiative legalizing the use of marijuana for recreational purposes, which will become law...more

Digital Currency Exchange Customers Targeted in IRS Information-Gathering Sweep

Coinbase, one of the largest digital currency exchange companies in the world, will likely be asked to provide the Internal Revenue Service (IRS) with transactional data and other information on all U.S. customers who used...more

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more

FinCEN: Cyber Events Should Be Reported via SARs

The Financial Crimes Enforcement Network (FinCEN) reminded banks that they are required to report cyber-enabled crime and cyber events just like any other suspicious activity. What happened - Observing that...more

Banks Should Prepare for Increased Collaboration between IT, Legal and BSA/AML Compliance Departments under New FinCEN Guidance

Last month, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued an Advisory which provided substantial guidance to financial institutions regarding the scope of information that must be...more

FinCEN Looks to Financial Institutions to File SARs Regarding Cyber-Events

On October 25, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory (the “Advisory”) explaining the obligations a “financial institution” might have under the Bank Secrecy Act (“BSA”) regarding...more

New Cybersecurity Reporting Requirements? FinCEN Advisory Identifies Cybersecurity Events for Financial Institutions to Report

Last week, FinCEN (Financial Crimes Enforcement Network) issued a formal Advisory to Financial Institutions and published FAQs outlining specific cybersecurity events that should be reported through Suspicious Activity...more

FinCEN Issues Advisory on the Reporting of Cyber-Events and Cyber-Enabled Crimes

The Financial Crimes Enforcement Network, or FinCEN, an arm of the United States Department of the Treasury, issued an advisory last week to remind financial institutions of their obligations to report cyber-events on...more

FinCEN Issues Advisory on Cyber Crime

On October 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published an Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime and an accompanying Frequently Asked...more

Don’t Roll the Dice: FinCEN Assesses Significant Penalties on Regulated Entity for Failing to Implement a Comprehensive AML...

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) imposed a civil money penalty of $12 million against a Nevada based casino, CG Technology, L.P. (CGT) for alleged violations of the Bank Secrecy Act...more

FinCEN Issues Advisory and FAQs Regarding Reporting Cyber-Events

The Financial Crimes Enforcement Network (“FinCEN”) has issued an advisory (“Advisory”) and Frequently Asked Questions (“FAQs”) to assist financial institutions in reporting cyber-events, cyber-enabled crime, and...more

Financial Services Weekly News - October 2016 #3

Editor's Note - Another Cybersecurity Proposal. On the heels of the New York State Department of Financial Services (NYDFS) issuing its proposed regulation that would require banks and insurance companies to institute...more

Upping the Ante on Casinos’ AML Compliance

FinCEN focus requires major shift in gaming business practices - Which complex, global industry where billions of dollars exchange hands every day, and where high-net-worth customers park significant sums, is facing...more

Regulatory Update and Recent SEC Enforcement Actions

On June 2, 2016, the SEC announced that it hired Christopher R. Hetner, a cybersecurity expert, as the Senior Adviser to the Chair for Cybersecurity Policy. The hire is indicative of the SEC’s focus on cybersecurity measures...more

De-Risking 101

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Cantor Gaming Forced to Pony up Millions for AML Violations: What Lessons Can Be Learned from FinCEN’s Latest Enforcement Action...

Action Item: Licensed gaming and other entities required to comply with the Bank Secrecy Act should be aware of this recent FinCEN enforcement action, and they must ensure that their compliance programs address the lessons...more

Don’t Gamble on Anti-Money Laundering Compliance

In August 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an advisory urging leadership within all U.S. financial institutions to actively promote a culture of compliance...more

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