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My money services business understands that Bank Secrecy Act regulations (31 C.F.R. Part 103) require, among other things, implementing a written anti-money laundering program and maintaining records of certain transactions. Because of the nature of my business, I would prefer to…
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…
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…
A Drug Enforcement Administration (DEA) investigation into a local cocaine and marijuana trafficker involved more than one cooperating source who knew of the trafficker but had no biographical data. A SAR was located that identified the trafficker, provided biographical data and notations that…
A defendant was sentenced to serve multiple months in prison followed by several years probation, after pleading guilty to narcotics trafficking charges and structuring financial transactions to evade the currency reporting requirements in connection with a marijuana growing operation. The…
An FBI investigation was initiated upon the receipt of a SAR from a bank in New York that identified deposits being structured to avoid the filing of CTRs. This case was worked jointly with the FBI, New York City Department of Investigation, IRS, and U.S. Customs Service. Over 80 SARs were filed…
In the course of an investigation into possible terrorist activities, investigators uncovered a SAR that provided detailed information concerning suspect check cashing activity by the operators of a convenience store. The filing bank’s audit found that the business was cashing checks to disguise…
