FinCEN has extended for another two years a conditional exception to the strict operation of the "Travel Rule" (31 CFR 103.33(g)). The Travel Rule requires a financial institution to include certain information in transmittal orders relating to transmittals of funds of 3,000 or more. This…
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The Financial Crimes Enforcement Network (FinCEN) receives numerous questions concerning compliance with the Bank Secrecy Act (BSA) recordkeeping requirement found in 31 C.F.R. §103.29. This section requires financial institutions to verify a customer’s identity and retain…
This serves notice that the Director of the Financial Crimes Enforcement Network (FinCEN) has granted a waiver from civil money penalties for violations of the Bank Secrecy Act, 31 U.S.C. 5314, and its implementing regulation, 31 C.F.R. Part 103.24, to persons who enter into settlement and…
The Financial Crimes Enforcement Network has an obligation to ensure that data collected under the Bank Secrecy Act are properly collected, securely maintained and appropriately disseminated. Following the unauthorized and unlawful disclosures of certain Suspicious Activity Reports to the press…
The U.S. Court of Appeals for the Sixth Circuit affirmed the conviction of David Middleton for attempting to evade or defeat income tax in violation of 26 U.S.C. 7201. The case arose from a SAR filed by a bank employee. Middleton was a real estate agent who formed several companies through which…
In a case initiated based on the filing of a SAR, a former high-ranking officer of an insurance firm, who was charged in a multiple-count federal indictment including counts of embezzling insurance premiums, falsifying records and filing false tax returns, has been sentenced to almost two years…