Compliance Blog

Written by Shari R. Pogach, Regulatory Paralegal 

FinCEN Shake-Up. The Financial Crimes Enforcement Network (FinCEN) has gone through a major reorganization under Director Jennifer Shasky Calvery.  The agency reorganization is meant to create more opportunities for cross training and greater staff interaction. Now, FinCEN’s employees are organized by job function:  financial intelligence analysts in the Intelligence Division, policy specialists in the Policy Division; liaison, outreach and call center personnel in the Liaison Division; and staff members responsible for exercising the agency’s regulatory enforcement authorities in the Enforcement Division.  According to Shasky Calvery, FinCEN’s new structure will allow information developed by an analyst in the Intelligence Division to be more easily provided to law enforcement, regulators, foreign partners and industry so all can better carry out their responsibilities.

FinCEN Administrative Announcements. Here are some additional FinCEN administrative announcements of interest: 

• The “Forms” webpage has been re-titled because almost all of FinCEN’s reports must now be e-filed.  The updated “Filing Information” page includes links to filing instructions, FAQs and the money services businesses (MSB) registrant search.  And, to avoid mistaken filings of sample forms, the agency has relocated them to its BSA E-Filing Test System.

• FinCEN acknowledged that credit unions may have administrative difficulties submitting Bank Secrecy Act (BSA) reports electronically within required timeframes due to natural disasters, emergency situations or other systemic issues in FIN-2013-G002.    On such occasions, credit unions should contact FinCEN’s Regulatory Helpline at 1/800-949-2732, or outside the U.S. at 1-703-905-3975, to inform the agency and determine possible alternatives for timely BSA reporting.  The agency will then work with credit unions to develop necessary alternatives.

• Individuals claiming to be employees of FinCEN and the U.S. Department of the Treasury have attempted to solicit funds from unsuspecting victims in ongoing financial scams.  FinCEN has issued an alert reminding the public to be wary of fraudulent correspondence and phone calls.  

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BSA Blast. And now, for a “shameless plug.” NAFCU’s July 2013 BSA Blast is available for NAFCU members.  For your reading pleasure this issue includes:

• The Liberty Reserve alleged money laundering case;
• FinCEN’s FAQ Resource on electronic filing; and
• A review of trends in Suspicious Activity Report filings
  concerning accountants and depository institution insider abuse.

And, naturally, the issue also includes the “Best of NAFCU’s BSA Blast Quizzes #3.”  You now have an additional twenty-five questions and answers at your disposal to stump train your staff on the BSA.

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Congressional Caucus. FinCEN Director Jennifer Shasky Calvery is speaking at NAFCU’s Congressional Caucus this September. The deadline for early-bird registration savings is this Friday, July 19. NAFCU members and nonmembers can save $100 on their registration fee by registering before the deadline. Caucus runs Sunday, September 8–Wednesday, September 11 at the Mayflower Renaissance Hotel in Washington, DC.