By Kyle Woodmansee

FinCEN released its second quarter Mortgage Fraud SAR Report. The report indicates that mortgage SARs continue to be on the rise and showed an increase from the first quarter report. I found this chart to be interesting:

It looks like FinCEN is preparing to save some trees. FinCEN has proposed a rule to make the electronic filing of reports required under the Bank Secrecy Act mandatory. FinCEN  stated that the move will improve efficiency, reduce costs, and enhance the ability of its investigators, analysts, and examiners to review the  reports. The proposed rule is open for comments and if implemented, would require e-filing as of June 30, 2012.

I was out in Colorado conducting a BSA training session with Andrea last week and I have to say that I never get tired of looking at the mountains.  Maybe that is because Iowa is not known for its changes in elevation, but I think it is more because I am all about the beauties of Mother Nature.

One discussion that we had while in Colorado was the reasoning behind the discrepancy in CTR filing requirements. It seems strange that a credit union must list  all joint account holders on a CTR for deposits of currency greater than $10,000 but only list the individual/s conducting the transaction for a withdrawal of currency greater than $10,000.

Is your credit union taking advantage of voluntary information sharing? Section 314(b) of the USA PATRIOT Act (31 CFR 103.110) allows credit unions to share information in order to identify and report suspicious activities that may involve money laundering or terrorist activity.  Privacy laws and regulations  prevent a credit union from sharing useful information with other financial institutions to combat terrorism and money laundering. Now FinCEN encourages credit unions to complete the 314(b) form, which will allow financial institutions to share information for a one-year period. Often times other financial institutions hold information that can be beneficial when trying to determine an appropriate course of action on potentially suspicious activity. Completing the 314(b) form could be a valuable tool in your BSA compliance arsenal.

Here are some key points:

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FinCEN has been busy lately. Here is what’s new:

FinCEN announced yesterday that it is now allowing for electronic filing of MSB registrations and optional electronic filing of the FBAR Form. In an age where paperless is the new norm, it is nice to see that they jumping on board.