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FinCEN, Bank Secrecy Act and planned developments.

FCRO Subsection: 
Contributor

Kenneth A. Blanco, Director, FinCEN (The Financial Crimes Enforcement Network, the USA's FIU and a division of the Department of the Treasury) sets out how Bank Secrecy Act data, including "convertible virtual currencies."

Inter-agency Working Group Efforts<
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Changing gears, I want to provide a brief update on the accomplishments of the working group established about a year-and-a-half ago between FinCEN, the OCC, FDIC, the Fed, and NCUA. We meet monthly in an effort to coordinate and improve the effectiveness and efficiency of the BSA/AML regime.

First, in October 2018, the group issued its joint statement on shared services to address instances in which banks may decide to enter into collaborative arrangements to share resources to more effectively manage their BSA and AML obligations.[1]

The joint statement acknowledges that banks and credit unions may benefit from using shared resources to manage certain BSA/AML obligations more efficiently and effectively.

We issued this statement after hearing from smaller institutions about the challenges and costs of BSA compliance. And while we have heard generally positive feedback, we would like to hear more about whether or not it has been helpful to your institution.

Then, in December 2018, the group issued a joint statement encouraging banks and credit unions to take innovative approaches to combating money laundering, terrorist financing and other illicit financial threats.[2]

Importantly, the joint statement noted innovative pilot programs in and of themselves should not subject banks to supervisory criticism, even if the pilot programs ultimately prove unsuccessful.

In July, the working group issued a joint statement as part of continuing efforts to improve transparency into their risk-focused approach to BSA/AML supervision.[3]

The risk-focused approach enables federal agencies to better tailor examination plans and procedures based on the unique risk profile of each bank. Again, we have generally heard positive feedback on this statement, but would welcome hearing about your specific experiences that can demonstrate the statement is achieving its intended result or why it is not.

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