If you’ve been paying attention, crypto/virtual currency has been coming up more and more.  Not only are financial institutions starting to see their customers take part in this but banks will also likely be faced with whether they want to get involved in crypto-asset activities in the future.  Is your BSA/AML program ready? 

On February 8^th, the Department of Justice announced the arrest of a New York couple for conspiring to launder stolen cryptocurrency.  Over $3.6 billion in cryptocurrency was seized in what was the DOJs largest ever financial seizure.  While the details of this scheme are quite complex, our “crypto guy”, Consultant Kevin Edwards, summarized it quite nicely during our recent webinar, “BSA/AML: Crypto/Virtual Currency”.  Check it out:

You can refer to the court filing for the charts discussed in the video.

If you are new to crypto/virtual currency or just want to learn more be sure to check out the webinar which is available now OnDemand. 

Some of the featured topics include:

• Crypto Lingo Crash Course: Exchanges and Miners and Tumblers, Oh My!
• Understanding and Assessing the Risks
• Updating Your BSA/AML Program
• Customer Due Diligence: What Questions Should You Be Asking?
• Ongoing Customer Due Diligence and Updating the Customer Risk Profile
• Enhanced Customer Due Diligence
• Red Flags for Virtual Currency Abuse and Spotting Unusual Activity 

Here is some of the feedback we received:

Great information! Our team learned so much!

All the information was great, there is so much to learn and a lot was covered!

I greatly appreciated the program and its contents as there are so many unknowns and players in this area.  It’s hard to comprehend sometimes and BCC makes it much easier!

I didn’t know too much about cryptocurrency. This information was great and very useful.

Published
2022/02/22

Tellers and Customer Service Representatives play a crucial role when it comes to developing a customer’s risk profile.  They are on the frontline working directly with the customer which gives them the ability to ask questions.  Knowing what to ask and when are vital to your BSA/AML program.

Kevin explains more in the video.

Ready to learn more?  JOIN US for our webinar, “BSA for Tellers & Customer Service Representatives”.  Featured topics include:

• Customer Identification Program
• Account Opening Customer Due Diligence
• Identifying Unusual Activity and Asking the Right Questions
• Performing & Documenting Customer Due Diligence
• Identifying, Verifying and Certifying Beneficial Owners of Legal Entity Customers
• Ongoing Customer Due Diligence and Updating the Customer Risk Profile
• Currency Transaction Reports & Monetary Instruments
• Suspicious Activity Reporting Requirements

Published
2022/02/11

The idea behind having a BSA Risk Assessment is to break down your bank’s BSA/AML risks into smaller, more manageable parts.  There is no specific methodology which means that each bank’s risk assessment can, and likely will, look different.  No two banks are the same.  The BSA Officer and your BSA Team play a crucial role in developing and updating your risk assessment.

Kevin explains more in the video.

Ready to learn more?  JOIN US for our webinar, “Bank Secrecy Act Officer/Team Responsibilities”.  Featured topics include:

• Current Events and Hot Topics
• Updates on AML Reform and the New Exam Manual
• BSA/AML & OFAC Risk Assessments
• Program Requirements (Controls, Testing, Training, Officer & CDD)
• Customer Identification Program
• Customer Due Diligence (Including the Beneficial Owner Rule)
• Currency Transaction Reports & Exemptions
• Suspicious Activity Reporting Requirements
• OFAC, 314(a) and 314(b) Requirements

Published
2022/02/07

Be sure to JOIN US for our webinar, “BSA/AML: Crypto/Virtual Currency.”

Crypto/Virtual currency is growing by leaps and bounds and is becoming more prevalent and mainstream.  If you haven’t seen it pop up yet at your institution, it’s probably only a matter of time.  If you haven’t conducted a risk assessment from a BSA/AML perspective, it’s something you are going to want to do.  Management needs to be aware of the potential risks as well as how to mitigate those risks as you move forward.

Kevin discussed crypto/virtual currencies at our January Monthly Connection.  Here is a short clip from that discussion.

ONE HOUR TRAINING

Featured Topics: 

• Crypto Lingo Crash Course: Exchanges and Miners and Tumblers, Oh My!
• Understanding and Assessing the Risks
• Updating Your BSA/AML Program
• Customer Due Diligence: What Questions Should You Be Asking?
• Ongoing Customer Due Diligence and Updating the Customer Risk Profile
• Enhanced Customer Due Diligence
• Is This Crypto Business A Money Service Business?
• Red Flags for Virtual Currency Abuse and Spotting Unusual Activity 

Designed for BSA/AML officers, teams, management, compliance officers, auditors, and other risk management personnel.

(1.25 Continuing Education credit hours)

PRESENTERS LIVE ON VIDEO!

NO CHARGE FOR ADDITIONAL LOCATIONS!

On January 24, 2022, FinCEN issued a Notice of Proposed Rule Making (NPRM) regarding the establishment of a pilot program for financial institutions to share Suspicious Activity Reports (SARs) and related information with foreign branches, subsidiaries, and affiliates.  This is required by Section 6212(a) of the Anti-Money Laundering Act of 2020.  The NPRM outlines several limitations and standards for such sharing.  Comments are due by March 28, 2022.

As you are likely already aware, institutions are generally prohibited from disclosing information contained within a SAR and/or even revealing the existence of a SAR.  In 2006, guidance was issued on sharing SARs with head offices and controlling companies along with additional guidance for the securities industry and mutual funds.  Again in 2010, there was guidance for depository institutions on sharing SARs with certain U.S. affiliates that are also subject to SAR filing obligations.  Any sharing under these present rules requires sufficient internal controls to protect the confidentiality of the SARs.  Since the pilot program is related to sharing information with foreign branches and subsidiaries, it brings with it additional concerns that are addressed in the NPRM. 

The pilot program would only be temporary but it’s intended to determine whether and how to propose future long-term legislation.  In order to participate in the program, a financial institution would need to submit an application identifying, among other things, the purpose(s) for sharing the information and how unauthorized disclosure will be prevented.  Participants would also have a quarterly reporting requirement.  The NPRM includes a detailed application process with rules and limitations for participants.

Again, comments are due by March 28, 2022, and may be submitted at:

• Federal E-rulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments. Refer to Docket Number FINCEN-2022-0002 and RIN 1506-AB51.

Published
2022/01/28