2020-05-18 | FinCEN Notice FIN-2020-NTC3Added · Updated
Financial institutions must not include pandemic-related challenges in Suspicious Activity Report narratives unless tied to suspicious activity, though previously filed reports with such references do not require correction. Institutions are required to maintain SAR supporting documentation for five years and provide it promptly upon request from FinCEN or law enforcement, verifying the requester's identity. The notice directs reporting of COVID-19-related fraud to specific agencies including the National Center for Disaster Fraud hotline, the FBI’s IC3, and the U.S. Secret Service. FinCEN has temporarily expanded its Rapid Response Program to assist in recovering funds stolen via fraud or cybercrime related to the pandemic.
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Notice Related to the
Coronavirus Disease 2019 (COVID-19)
The Financial Crimes Enforcement Network (FinCEN) is issuing this Notice as part of FinCEN’s COVID-19-related response. This Notice contains pertinent information regarding reporting COVID-19-related criminal and suspicious activity and reminds financial institutions of certain Bank Secrecy Act (BSA) obligations. FinCEN intends to issue multiple COVID-19-related advisories. Each advisory will refer financial institutions to this Notice. COVID-19-Related Updates to Financial Institutions FinCEN has published notices on its website that provide information to assist financial institutions in complying with their BSA obligations during the COVID-19 pandemic, which include a direct contact mechanism for urgent COVID-19-related issues. FinCEN encourages financial institutions to monitor FinCEN’s website and the Department of the Treasury’s website on The Coronavirus Aid, Relief, and Economic Security (CARES) Act for up-to-date information concerning compliance with BSA obligations.1 BSA Reporting Obligations Compliance with the BSA remains crucial to protecting our national security by combating money laundering and related crimes, including terrorism and its financing. FinCEN expects financial institutions to continue following a risk-based approach and to diligently adhere to their BSA obligations. FinCEN also appreciates that financial institutions are taking actions to protect employees, their families, and others in response to the COVID-19 pandemic. FinCEN recognizes that current circumstances may create challenges with respect to certain BSA obligations, including the timing requirements for certain BSA report filings. FinCEN will continue outreach to regulatory partners and financial institutions to ensure risk-based compliance with the BSA, and FinCEN will issue additional information as appropriate.2
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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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