On April 1st, we alerted you to Currency Transaction Report (CTR) changes related to transactions with sole proprietorships and legal entities operating under a “doing business as” (DBA) name. These changes were set to take effect earlier this week on April 6th (September 1st for e-filing batch reporters).
FinCEN Change of Plans
On April 3rd, however, FinCEN announced that these changes would be suspended until further notice. In the meantime, financial institutions should continue to report these transactions as they do currently OR if the changes have already been implemented, they may continue to comply with the requirements in the suspended ruling.
BSA Doesn’t Go Away!
On a side note, do not forget about BSA during these uncertain times! Although FinCEN recognizes that COVID-19 has presented many challenges, this announcement reiterated that they do expect financial institutions to continue following a risk-based approach, and to diligently adhere to their BSA obligations. In the last couple of weeks, we’ve seen that things seem to change almost daily and FinCEN stated they will provide updates, as appropriate.
We encourage you to check out the COVID-19 resources on our website. We also have a variety of BSA webinars, tailored to specific personnel, to assist you in your overall BSA compliance training efforts.
Want free BSA tools? See – https://store.bankerscompliance.com/link/BSAFreeTools
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!