Music, I'm Gloria Leduc, here on the CU Compliance Connection by League Info site, bringing you a brief overview of FinCEN's new rule for customer or member due diligence requirements for financial institutions. Compliance with these new rules is required on May 11th of this year. With multiple frequently asked questions issued by FinCEN, we thought it would be a good idea to provide a high-level summary and overview. Back in 2016, FinCEN or the Financial Crimes Enforcement Network issued new rules under the Bank Secrecy Act or BSA to clarify and strengthen customer due diligence requirements for financial institutions. These new rules created a new requirement for credit unions to identify and verify the identity of beneficial owners of legal entity customers or members. There were also changes to anti-money laundering or AML program requirements which will require credit unions to implement and maintain appropriate risk-based procedures for conducting ongoing member due diligence for all members. This includes first understanding the nature and purpose of the customer or member relationship and conducting ongoing monitoring to identify and report suspicious transactions, as well as maintaining an updated member or customer information. Therefore, in order to comply with the new rules, which is required on or before May 11th, credit unions need to make sure their member or customer due diligence program is updated. This includes the requirement to identify and verify the beneficial owners of legal entities and update their overall AML program to include risk-based procedures for conducting ongoing due diligence for all members. So, how will these changes impact the credit unions' existing processes? First, after May 11th, when legal entity members come in to open a new account, the credit union will need to obtain certain information from them in order to identify those beneficial owners. Now, the...
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Fincen Sar update Form: What You Should Know
United States federal, state and territorial laws must use the new SAR report format and a new reporting form, known as the Revised Suspicious Activity Report (SAR). Read the latest version and review the FAQs and instructions in the SAR report and report filing guidelines. New Guidance “The form [revised SAR] and the reporting requirements do not change substantially from the previous reporting form or format. Further, there is no significant change in the types of information to be reported, nor will there be any change in the ways to report suspicious activity. The format of the forms and instructions are the same. The SAR form provides all the information required by law.” bureau of Consumer Financial Protection, Suspicious Activity Reporting Guide and Guidance, June 20, 2006 “The revised SAR is similar to the previous reporting format and the information to be reported is identical. As is the case with the previous filing format, these requirements do not increase significantly in terms of time or resources necessary to comply.” bank Secrecy Act Information, Report Regulatory Changes to Suspicious Activity Reports in FY2013: “In February 2006, the Treasury issued final regulation on Suspicious Activity Reports (SARS), effective on March 28, 2006. In 2007, the Treasury issued final regulations on SAR procedures, effective immediately. In February 2010, the Treasury issued amendments to the regulations on SAR's and the Treasury issued final regulation on SAR requirements, effective immediately.
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