Blog — Compliance Cohort

On October 10, 2024, the OCC announced a cease and desist order and a $450 million civil money penalty against TD Bank, N.A. and TD Bank USA, N.A., for deficiencies in the bank’s BSA and AML compliance program. The OCC determined that the bank failed to develop and maintain a BSA/AML program reasonably designed to assure and monitor compliance with the BSA and its implementing regulations.

Oct 1
Oct 1 FinCEN Withdraws AML Findings Against ABLV Bank

On September 26, 2024, FinCEN submitted a notice to the Federal Register withdrawing its finding that ABLV Bank, AS (ABLV) is a financial institution of primary money laundering concern. FinCEN also rescinded the related notice of proposed rulemaking (NPRM) seeking to impose special measure five pursuant to section 311 of the USA PATRIOT Act (section 311).

Oct 1
Oct 1 Treasury Cracks Down on Illicit Russian Virtual Currency Exchanges and Cybercrime Facilitator

On September 26, 2024, the U.S. Department of the Treasury announced that it is undertaking actions as part of a coordinated international effort to disrupt Russian cybercrime services. In line with this, FinCEN has issued an order that identifies PM2BTC as being of “primary money laundering concern” in connection with Russian illicit finance.

Sep 23
Sep 23 FinCEN Issued Beneficial Ownership Reporting Outreach and Education Toolkit

On September 19, 2024, FinCEN issued another resource to familiarize small business owners with beneficial ownership reporting requirements. The toolkit includes general background on the reporting requirements, as well as templates for newsletters, websites, and emails; sample social media posts and images; and information on how to contact FinCEN.

Sep 17
Sep 17 FinCEN Proposes Renewal of Monetary Instruments Recordkeeping Rule

On September 17, 2024, FinCEN issued a notice and request for comments on the proposed renewal, without change, of existing information collection requirements found in BSA regulations that require financial institutions to maintain records related to the issuance or sale of bank checks and drafts, cashier's checks, money orders, and traveler's checks when the issuance or sale involves the use of currency in an amount between $3,000 and $10,000, inclusive.

Sep 16
Sep 16 OCC Takes Action Against Wells Fargo Bank

On September 12, 2024, the OCC entered into a Formal Agreement with Wells Fargo Bank, N.A. The agreement requires the bank to take comprehensive corrective actions to enhance its Bank Secrecy Act/anti-money laundering and U.S. sanctions compliance programs.

Sep 11
Sep 11 FinCEN Updates BOI FAQs

On September 10, 2024, FinCEN updated its Beneficial Ownership Information Frequently Asked Questions anew. The FAQs are issued in response to inquiries received relating to the BOI Reporting Rule and BOI Access and Safeguards Rule.

Sep 10
Sep 10 FinCEN Issues In-Depth Analysis of Check Fraud Related to Mail Theft

On September 9, 2024, FinCEN issued a Financial Trend Analysis (FTA) on mail theft-related check fraud incidents based on BSA data filed between February 27 and August 31, 2023. FinCEN received 15,417 BSA reports from 841 financial institutions on mail theft-related check fraud, amounting to more than $688 million in reported suspicious activity.

Aug 29
Aug 29 FinCEN Issues Final Rules to Counter Illicit Finance and Security Threats in Investment Adviser Sector