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| Date |
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| July 2008 |
FinCEN Proposes Revisions to CTR Exemption Procedures |
| June 2008 |
“Foreign Corruption” Should Be Spelled Out in SAR Narratives, If Present |
| May 2008 |
Wire Transfer Requirements Subject to Further Elaboration by the FATF |
| April 2008 |
Precious Metal, Stone, and Jewel Dealers Advised on Risks of Foreign Suppliers |
| March 2008 |
Presenting Negotiable Instruments Does Not Create Correspondent Account |
| February 2008 |
Lender’s Cashing of Checks For Borrowers Does Not Make It a Check Casher |
| January 2008 |
12th SAR Activity Review Looks at Credit Card Checks, Credit Union Cooperatives, and Law Enforcement Successes |
| December 2007 |
FinCEN Finds Persistent Failures in SAR Filings by Many MSBs |
| November 2007 |
Enhanced Correspondent Account Due Diligence Rules Finalized |
| October 2007 |
FATF Mutual Evaluation of China Finds Progress, Also Significant Deficiencies |
| September 2007 |
Transaction Reporting Changes for Casinos Finalized by FinCEN |
| August 2007 |
FinCEN Issues SAR Activity Review, Issue 11 |
| July 2007 |
Customer ID Program Guidance for FCMs in Give-Up Arrangements Issued |
| June 2007 |
Macau Bank Helping North Korean Counterfeiters Gets Pariah Status, But FinCEN Releases Frozen Funds Weeks Later |
| May 2007 |
FATF Plenary Session Grants India Observer Status |
| April 2007 |
Suspicious Activity Reports Revised For Joint Filings |
| March 2007 |
Jurisdictional Overlaps and Lack of Coordination Plague Partnership of IRS and FinCEN in BSA Enforcement |
| February 2007 |
Bank Selling Insurance as Agent Does Not Open Accounts for CIP Purposes |
| January 2007 |
Currency Transaction Reporting to Be Studied by OCC |
| December 2006 |
Mutual Fund Suspicious Activity Reporting Subject of FinCEN FAQs |
| November 2006 |
New Materials Added to FFIEC Exam Manual Describe Automated Clearing House and Other Requirements |
| October 2006 |
Mutual Evaluation of U.S. AML and Counter-Terrorism Efforts Throws Mix of Soft and Hardballs |
| September 2006 |
FinCEN’s Focuses Attention on MSBs in 10th SAR Activity Review |
| August 2006 |
FinCEN’S SAR By the Numbers Report Notes Increase in Market Manipulation |
| July 2006 |
Cashing Its Own Checks Does Not Make a Business a Check Casher |
| June 2006 |
BSA Compliance Rules for Edge Act and Agreement Corporations Finalized |
| May 2006 |
OFAC Provides Best Practices for Bank Compliance, Details Review Procedures |
| April 2006 |
Chief Counsel Considers When Offshore Credit Card Accounts Are Financial Accounts for FBAR Reporting and Penalties |
| March 2006 |
Final Due Diligence Rules on Correspondent and Private Banking Accounts Issued The use of correspondent and private banking accounts for money laundering was a concern before the PATRIOT Act, but Section 312 of the Act required U.S. financial institutions to establish due diligence policies, procedures, and controls reasonably designed to detect and report money laundering through such accounts. |
| February 2006 |
Terrorism Risk Insurance Extension Act Keeps Program Alive Two More Years;
The Terrorism Risk Insurance Extension Act of 2005 (“Extension Act”)1 extends the federal safety net for insurers for two years, but expands the private sector role and reduces the federal share of compensation for insured losses under the program. |
| January 2006 |
U.S. Terrorist Financing Strategy Found Deficient;
In Terrorist Financing: Better Strategic Planning Needed to Coordinate U.S. Efforts to Deliver Counter-Terrorism Financing Training and Technical Assistance Abroad,1 the Government Accountability Office found the U.S. government “lacks an integrated strategy to coordinate the delivery of counter-terrorism financing training and technical |
| December 2005 |
Inspector General Reports Widespread Failure to Register by MSBs;
In Bank Secrecy Act: Major Challenges Faced by FinCEN in Its Program to Register Money Services Businesses,1 the Treasury Inspector General found “indicators that many MSBs required to register had not done so.” The OIG Report acknowledged a 37% increase in registrations between January 2004 and January 2005, a numerical increase from 16,142 to approximately 22,000, with no enforcement actions taken against noncompliant MSBs. |
| November 2005 |
Comptroller Discusses Effects of Uniform Examination Procedures; John C. Dugan, Comptroller of the Currency, in a speech delivered before the American Bankers Association/American Bar Association Money Laundering Enforcement Conference on November 1, 2005,1 stated that the OCC is applying the new uniform examination procedures in all bank examinations. |
| October 2005 |
The recently issued FFIEC BSA/AML Examination Manual is more detailed than prior exam manuals issued by the banking regulators separately, particularly as to issues involving electronic operations, organizational structures, and relationships with other financial institutions. |
| September 2005 |
Three Recent FinCEN Rulings Refine Definition of MSB; Continuing its trend to providing piecemeal but almost immediate guidance on Bank Secrecy Act issues, FinCEN recently released three rulings describing borderline situations where a business might, or might not, be an MSB. |
| August 2005 |
Seven New Members to Egmont Group;
The Egmont Group, which met from June 27 to July 1 in Washington, D.C., admitted seven new members: Bosnia/Herzegovina, Honduras, Peru, Philippines, Montenegro, Qatar, and San Marino. This brings the total membership of the ten-year old organization to 101. The tenth anniversary meeting was hosted by FinCEN.1 |
| July 2005 |
A financial institution for purposes of the Bank Secrecy Act includes, under 31 U.S.C. 5312(a)(2)(N), “a dealer in precious metals, stones, or jewels.” On April 29, 2002, FinCEN deferred anti-money laundering program requirements for such entities.1 On June 3, the Financial Crimes Enforcement Network posted interim final rules describing the anti-money laundering programs that must be established by dealers in jewels, precious metals, or precious stones.2 The effective date is July 11. |
| June 2005 |
Guidance on Customer ID Programs Provided by FinCEN, Banking Agencies Special Measures Proposed for Two
Latvian Banks,
Electronic Filing of SARs and
CTRs Continues to Grow,
Agroterrorism Seen as Continuing
Threat in GAO Study,
SAR Narratives Often Inadequate,
FinCEN Finds,
FATF Website Redesigned |
| May 2005 |
Eighth SAR Review Talks About “Racinos,” National Security
Letters, Other Trends and
Developments,
Pinochet Matter Continues to Fuel Investigations,
FinCEN Proposes SAR for MSBs,
State Department Lists Countries
of Primary Concern for Money
Laundering |
| April
2005 |
FinCEN Issues 2004 Annual Report; FCMs and Introducing
Brokers May Rely on CTAs to Perform CIP; Cook Islands, Philippines Advisories
Withdrawn; BSA Exam Guidelines Revisions Expected; OCC Unauthorized Bank
List; UN Terrorist List Can Supplement SDN List; Companies Associated With
Jamaican Drug Kingpin Designated |
| March
2005 |
Cook Islands, Indonesia, and the Philippines Removed
from NCCT List; FATF Issues Additional Guidance on 9th Special Recommendation;
SAR Activity Review Statistical Data Updated; FinCEN Releases 2006-2008
Strategic Plan; Arellano Felix Organization Described by Treasury |
| February
2005 |
Intelligence Reform Act Gives New Power to FinCEN,
Other Agencies; FinCEN Revises MSB Registration Form; Secure Web System
for 314(a) Communications Launched by FinCEN |
| January
2005 |
Interpretive Guidance Describes AML Programs of
Money Services Businesses; Unitary Filing of Suspicious Activity and Blocking
Reports Detailed in Interpretive Guidance; Narcotics Trafficking List Expanded
To Include More Columbian Drug Lord Agents; Cali Cartel Financial Network
November 2004 |
| December
2004 |
OCC Issues Enforcement Guidance on Issuing Cease-and-Desist
Orders for BSA Violations; Foreign Financial Account Reporting Penalty Can
Now Be Imposed Without Willfulness; OFAC Adds Peruvian Airline to Kingpin
List; Survivor Vanuatu: State Department Lists Offshore Financial Centers |
| November
2004 |
FATF Adds Ninth Special Recommendation; FATF Withdraws
Counter- Measures Against Myanmar and Nauru; Two New Regional Groups Being
Formed; Increase in Defensive Filings Noted by FinCEN; 314(a) Statistics
Released; UK Considers Revisions to Customer ID Procedures |
| October
2004 |
AmSouth Bank Fined $10 Million For BSA Violations,
Prosecutions Deferred; China Increases Money Laundering Effort; Shift to
Counterterrorism Priorities May Have Reduced FBI’s Drug Enforcement
Efforts |
| September
2004 |
Seventh SAR Activity Review Released; Shell Corporations
and Shell Banks; Food Stamp Fraud; International Cash Letters; Refund Anticipation
Loan Fraud; Suspicious Activity Reporting by Broker-Dealers; ATMs Can Avoid
Bank Secrecy Reporting |
| August
2004 |
SEC Finds No Evidence of Trading Patterns Indicating
Advance Knowledge of 9/11; Report Slams Riggs Bank AML Implementation, Regulators
on Enforcement; India AML Progress Analyzed by Drs. J.D. Agarwal and Aman
Agarwal; FinCEN Magnetic Media Filing Specifications Updated; SIA Comments
on Special Measure Against Commercial Bank of Syria; Customer Identification
Program Exam Procedures Described by Bank Regulators |
| July
2004 |
FATF Issues Annual Report, Announces Initiatives;
Fifth Annual Review of Non-Cooperative Countries or Territories Released
by FAFF; Guatemala Dropped from List; Interpretive Guidance Focuses on Terrorist
Financing; Supervisory Agencies Provide Tepid Encouragement For Financial
Services To Embassies and Foreign Governments; FinCEN Reinstates Information
Sharing with Mexico; Phishing Hits OCC |
| June
2004 |
Riggs National Bank Assessed $25 Million For BSA
Violations; Terrorism Risk Insurance May Not Continue Without Government
Support; FATF Renews Mandate for Eight Years; FinCEN Summarizes Protections
for SAR Filers; Phishing Schemes Nearly Doubling EveryMonth |
| May
2004 |
Foreign Currency Exchanger Does Not Become MSB
By Keeping Account In U.S.; Special Measures On Burma Imposed; Two Syrian
Banks Designated Of Primary Money Laundering Concern; FinCEN Director Describes
Coming Releases, Developments; Treasury Department Requests Comments On
Whether To Extend “Make Available” Requirements of Terrorism
Risk Insurance Act; SAR Statistics Released; GAO Finds Cargo Containers
A Continuing Security Threat |
| April
2004 |
No-Action Letter Opens Door For Broker-Dealers
to Rely on Investment Advisers for Customer Identification Requirements;
International Narcotics Control Strategy Report Released; Advisories on
Egypt, Ukraine Withdrawn; Financial Services Authority Fines Austrian Bank;
FinCEN Proposes Two Currency Transportation Forms |
| March
2004 |
New Money Laundering Typologies Report Released
by FATF; Ukraine and Egypt Removed from Non-Cooperative Countries and Territories
List; National Strategies Related to Terrorism Evaluated by GAO; Money Services
Business Registration List Added to FinCEN Website; District Court Protects
Bank’s SAR-Related Records |
| February
2004 |
FinCEN Provides Guidance on Suspicious Activity
Reporting for Casinos; GAO Says FBI Should Study Terrorists’ Use of
Alternative Financing Mechanisms; Customer Identification Program FAQs Provided
by Agencies; Comment on Real Estate Closers Made by Bureau of Alcohol, Tobacco,
Firearms and Explosives; FinCEN Warns of Anti-Terrorist Certificate Scam |
| January
2004 |
Final Rules Require FCMs and Introducing Brokers
to File SARs; New Currency Transaction Report Form Issued; National Money
Laundering Strategy Restated for 2003; Claims Procedures under Terrorism
Risk Insurance Act Proposed; Broker-Dealer Fined for Foreign Shell Bank
Correspondent Accounts; FinCEN Reiterates Requirements for Ruling Requests;
Contact Information of National Banks To Be Processed Electronically |
| December
2003 |
GAO Finds Leadership, Priorities, and Accountability
Deficient in National Money Laundering Strategy; CD for MSBs Provides Educational
Tools, Forms, and Contact Information; New SAR Activity Review Released;
Travel Rule Exception Expires Permanently |
| November
2003 |
Examination Procedures Specified on Foreign Shell
Banks and Information Sharing; FinCEN Report Looks At Seven Years of SAR
Filings; Small Changes to Interim Terrorism Risk Insurance Rules; Financial
Institutions Reacted Effectively to August Blackout; James Sloan Leaves
FinCEN; Terrorist Supporter Allegedly Connected With Lichtenstein Bank |
| October
2003 |
FATF Focuses on Freezing Terrorist Assets; Customer
Identification Rules Do Not Require Retention of Photocopies and Do Not
Preclude Foreign Government Issued IDs Other Than Passports; FinCEN’s
Freedom of Information Act and Privacy Act Procedures Modified for Bureau
Status |
| September
2003 |
Treasury Touts Progress Against Terrorist Financing;
UK Financial Services Authority Considers Changes to Customer Identification
Standards; GAO Report Recommends Improvements to Information Sharing Procedures;
GAO Warns of Vulnerabilities at Land Border Points of Entry |
| August
2003 |
Treasury Adopts Final Terrorism Risk Insurance
Program Rules, Making Minor Modifications to the Interim Version |
| July
2003 |
FATF Releases New Forty Recommendations; Other
Developments Mark Plenary Meeting |
| June
2003 |
Edge and Agreement Corporations Subject to Be Subject
to BSA Under Proposed Rule |
| May
2003 |
Investment Advisors and Commodity Trading Advisors
to be Required to Implement Anti-Money Laundering Programs |
| April
2003 |
Terrorism Risk Insurance Program Takes Shape through
Interim Rules |
| March
2003 |
Jewelers and other Dealers Required to Implement
Anti-Money Laundering Programs |
| February
2003 |
Currency Dealers and Exchangers Now Required to
File Suspicious Activity Reports |
| January
2003 |
Suspicious Activity Reporting for Mutual Funds
Contained in Proposed Rules |
| December
2002 |
Treasury Report Acknowledges Difficulties in Identifying
Foreign Nationals |
| November
2002 |
Hedge Funds and Other Unregistered Investment
Companies Will Soon Be Required to Establish Anti-Money Laundering Programs |
