Private Flood Insurance Q&As

On March 11, 2021, the Agencies announced new proposed guidance related to flood insurance in the form of Interagency Questions and Answers (Q&As).  This included 24 new proposed Q&As just on private flood insurance.

We get questions all the time on private flood insurance and one question we get quite frequently is what documentation is needed from a private insurer beforehand to make sure that the policy is acceptable under the law and so that everything goes smoothly?

Kevin explains the answer in the video.


Tailored BSA Training

Training is one of the most important aspects of your BSA/AML program.  The Bank Secrecy Act requires you to conduct training for all personnel including your Board of Directors.  The key to effective BSA training is to keep things fresh and interesting, as well as, relevant to their specific duties.  Without proper training no matter how good your policies and procedures are, they really don’t mean a whole lot if your people don’t understand what they’re supposed to be doing and/or what they’re supposed to be looking for.

Kevin explains more in the video


BSA Compliance: Helpful Resources

Information to help with BSA compliance

Complying with the Bank Secrecy Act is constantly evolving and changing.  The bad guys always come up with new ways to lie, cheat and you are charged with the important task of mitigating risk, as well as detecting, preventing, and reporting suspicious activity.  Some of the more recent areas of BSA focus have been fraud/scams related to the COVID-19 pandemic (i.e., unemployment, health insurance, PPP, vaccines, etc.), cannabis law (marijuana, hemp, etc.), human trafficking, and more.

BSA Compliance: Helpful Resources

Other resources you may find helpful are:

The Bank Secrecy Act Regulation – 31 CFR Chapter X

FFIEC’s BSA/AML Examination Manual

Financial Crimes Enforcement Network (FinCEN)  

Your Federal Regulator’s website:

FDIC / OCC / Federal Reserve / NCUA


Money Laundering/Terrorist Financing Red Flags

If you are in the BSA world, you’ve likely been seeing the acronym “ML/TF” quite a bit recently.  If you’re not in the BSA world, ML/TF refers to “money laundering, terrorist financing”.  This was a new term added to FinCEN’s BSA/AML Examination Manual to help guide institutions to hone in on risk associated with these specific types of activity, in addition to other illicit financial activity risk.  FinCEN also put together a list of ML/TF red flags which we’ve turned into a tool in the Free BSA/AML Tools on our website.  This can be used in training for applicable personnel, as well as, a checklist of sorts to see if your program is capable of identifying some of the specified activity.

Find your BSA ML/TF FREE Tool HERE!

Kevin explains more about ML/TF in the video.

Use the search function under the Product Files to find a specific tool.


BSA/AML Exam Manual Revisions

BSA/AML Exam Manual Revisions

On February 25, 2021, the FFIEC announced revisions to the BSA/AML Examination Manual. 

Specifically, the FFIEC added a new introduction in the “Assessing Compliance with BSA Regulatory Requirements” section and made revisions to three additional sections:

1) Customer Identification Program;

2) Currency Transaction Reporting; and

3) Transactions of Exempt Persons

It’s important to remember this manual serves as a guide for examiners when determining whether an institution’s BSA/AML compliance program is adequate. If you want to know what the examiners will be looking at during your next BSA/AML exam, this is where you want to look for guidance.

These new and revised sections do not impose any new requirements, but they do offer further transparency into the examination process and support risk-focused examination work. All of the revisions are identified by a 2021 date on the FFIEC BSA/AML InfoBase

Be sure to check out our monthly magazine, Banking on BCC, as we plan to take a closer look at these revisions in an upcoming issue.