Links in “FinCEN”

Although many financial institutions are still wary to serve legal marijuana-related businesses due to current risk of enforcement, some institutions have begun seeking such service following positive guidance issued by both the Department of Justice and FinCEN. [9/30/15]

Commenter to this blog post about the FinCEN director's recent speech wondering why so many credit unions haven't filed a single CTR or SAR for the past seven quarters offers this possible explanation: many of their members are of modest means and don't deal with $10,000 in cash. "Thus, Madam Director, it makes sense that many credit unions have not filed CTRs in the last two years - if not five, if not ever." [9/18/15]

If it's been awhile since your credit union has filed a CTR or a SAR, now might be a good time to double check your system. FinCEN's director says it is investigating why a high number of credit unions haven't filed either CTRs or SARS in some time. She warns that smaller institutions don't get a pass because of their size, noting that criminals often target smaller institutions as "the weakest link." [9/16/15]

Proposed FinCEN rules would require investment advisers to establish written anti-money laundering programs, report suspicious activity and follow recordkeeping requirements. How might this impact your credit union? [9/11/15]

…except this time. FinCEN has charged Caesars Palace $8 million for willful and repeated violations of the Bank Secrecy Act. Specifically, the casino was cited for turning a blind eye to its high rolling customer’s activity. [9/10/15]

FinCEN has renewed its Geographic Targeting Order (GTO) in Southern California, and has placed a new GTO on eight major ports in Texas. The reasoning? The enhanced transparency of cross-border money movements. [8/10/15]

FinCEN has passed a final rule which implements the fifth special measure against FBME Bank, a Middle Eastern bank which was cited as a money laundering concern back in July of 2014. [7/29/15]

FinCEN is expected to release new enhanced due diligence requirements in August. The four key elements the new rule will address are: (1) identifying and verifying member identity; (2) verifying identity of beneficial owners of business entities; (3) understanding the nature and purpose of member relationships; and (4) conducting effective ongoing monitoring for suspicious activity. [6/17/15]

FinCEN announced a $75 million civil penalty against Hong Kong Entertainment (Overseas) Investments and Tinian Dynasty Hotel & Casino for failure to develop and implement an AML program. The casino went years without an AML program in place, willfully conducted suspicious transactions, and offered advice for avoiding laws in the U.S. [6/4/15]

The Wall Street Journal has reported that a confidential FinCEN report identifies more than 50 credit unions as being vulnerable to money laundering.  While not citing any wrongdoing on the part of these credit unions, FinCEN is concerned that these institutions may not have sufficient due diligence and monitoring systems in place to address an increase in the use of smaller institutions by both money services business (that launder money) and drug traffickers. [6/3/15]