Joint Agency Guidance Highlights BSA/AML Priorities

July 2, 2021 at 9:42 am Leave a comment

Good morning folks, on Wednesday, federal and state regulators, including the NCUA, took the first step to implement federal law intended to streamline the BSA framework for financial institutions when they issued a list of priorities to consider when monitoring financial activity. 

Last year’s defense authorization bill (H. R. 6395—1162) contained a provision intended to make the federal government better prioritize areas of BSA enforcement and better coordinate the activities of state and federal regulators and financial institutions.  The priorities announced yesterday are the first step in this process, the next step is for FinCEN to translate these priorities into specific regulations, nevertheless, in a joint statement the regulators explained that “in preparation for any new requirements when those final rules are published, banks may wish to start considering how they will incorporate the AML/CFT Priorities into their risk-based BSA compliance programs, such as by assessing the potential related risks associated with the products and services they offer, the customers they serve, and the geographic areas in which they operate.”

The list includes general categories such as countering corruption and terrorist financing, it also addresses more specific concerns such as cyber currencies and human trafficking.

Maybe I am getting jaded but as I review FinCEN announcements, I can’t help but think it’s foolish to impose the same regulatory framework on a $50 million credit union with a defined Field of Membership as Bank of America.  Hopefully this can be the first step in promulgating rules which make common sense distinctions between international money lenders and community based institutions.

Enjoy your 4th of July weekend.  For you Giants fans, remember, don’t do a JPP as you set off the fireworks. 

Entry filed under: Compliance, Federal Legislation, Regulatory. Tags: , , .

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Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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