The staff of the Commodity Futures Trading Commission (“CFTC”), Financial Crimes Enforcement Network (“FinCEN”), and the United States Department of the Treasury (“Treasury”) are issuing these questions and answers (“Q&As”) regarding the application of 31 C.F.R. § 103.123. This joint rule…
Guidance
Banks, thrift institutions, bank holding companies and non-bank subsidiaries, credit unions, the U.S. branches and agencies of foreign banks, and certain other financial institutions are required to file Suspicious Activity Reports (SARs) pursuant to regulations issued by the five federal…
The staff of the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, National Credit Union Administration, Office of the Comptroller of the Currency, Office of Thrift Supervision, and the United States Department of the…
PowerPoint Presentation Downloading and Viewing Instructions
FinCEN, in consultation with the federal regulatory authorities, has issued a guidance package designed to assist financial institutions in the preparation of Suspicious Activity Report (SAR) forms and to improve the quality of…
Q. Broker-dealers engage in transactions through omnibus accounts and sub-accounts established by financial intermediaries. In these situations, (1) the omnibus account or relationship is established by or on behalf of a financial intermediary for the purpose of executing…
1. Is a business that cashes a check with a face value of over $1,000 by providing the customer with $999 in currency and the balance in money orders or a wire transfer a “check casher” for Bank Secrecy Act (BSA) purposes?
For purposes of application of the BSA, certain…
This is a reminder that as of July 1, 2000, depository institutions must use the reformed Currency Transaction Report ("CTR") exemption regulations for exemptions established prior to October 21, 1998 as well as exemptions established after that date, in accordance with 31 C.F.R. Part 103.22 (d…
FinCEN receives numerous questions from depository institutions regarding the applicability of exemptions from filing Currency Transaction Reports (CTRs) for tribally owned and operated casinos in accordance with the Bank Secrecy Act (BSA), 31 U.S.C. §5311 et seq., and its implementing…
Background
Bank Secrecy Act regulations require depository institutions to file with FinCEN currency transaction reports (CTRs) on transactions in currency of more than $10,000 (large currency transactions). See 31 C.F.R. § 103.22. However, the provisions of 31 C.F.R. §103.22(d)…