Attorneys examine US regulator moves to finalize rules, plus expectations and efforts of the compliance community in preparing for them.
Rule Overview
Jurisdiction: United States
Regulator: Office of Comptroller of the Currency (OCC)
Topic: Risk Management
12 CFR 21.21Who it applies to: National banks and savings associations.
Purpose: Requires institutions to establish and maintain programs that monitor and ensure compliance with Bank Secrecy Act (BSA) recordkeeping and reporting requirements.
Written program: The BSA compliance program must be documented in writing, approved by the board of directors, and reflected in board minutes.
Customer identification: The program must include a Customer Identification Program (CIP) to verify customer identities when opening accounts.
Minimum program elements:
Attorneys examine US regulator moves to finalize rules, plus expectations and efforts of the compliance community in preparing for them.
Document answers two new FAQs and updates another, addressing CIPs and use of government-issued verifiable digital credentials.
The growing number of such scams, FinCEN said, are largely perpetrated by transnational criminal organizations operating "industrial-scale scam compounds" with networks of criminal actors.
The main message: Banks need to take certain precautions when discussing information that could reveal the existence of a SAR.
FinCEN and banking regulators seek to establish the minimum standards for a payment stablecoin issuer's customer identification programs.
NYDFS guidance directs banks to use blockchain analytics tools to mitigate money laundering and sanctions evasion risk if they’re conducting cryptocurrency-related transactions.
New rulemaking is being developed to apply Bank Secrecy Act standards to stablecoin issuers and digital asset platforms.
The rule places RIAs and ERAs under Bank Secrecy Act-style compliance obligations.