April 8th, 2021

BSA - Upcoming Changes and Challenges - WST

As Americans we often see the United States as the constant leader on a global scale - be it in athletic competitions, industry, military strength, or just good ol' American ingenuity. However, the United States has consistently received a failing grade regarding certain aspects of its standards for combatting money laundering and terrorist financing. As a matter of essential national security, Congress has recently committed to strengthening U.S. anti-money laundering/terrorist financing practices as a top priority.

Enter the Corporate Transparency Act (CTA) passed by Congress earlier this year and enacted into law as part of the National Defense Authorization Act 2021. The CTA establishes a new framework related to beneficial ownership reporting, maintenance, and disclosure at a national level. FinCEN has until January 1, 2022 to promulgate associated regulations and, as a result, published an advance notice of proposed rulemaking (ANPRM) in the Federal Register on April 5, 2021. The ANPRM seeks input from industry stakeholders, including financial institutions, regarding these upcoming changes.

So, exactly what does this mean for your institution? Several things, but first and foremost, it means changes are coming. However, like all other regulatory-related changes, it won't be immediate. To begin with, consider whether your institution would like to respond to the ANPRM - there are 48 questions and you have until May 5, 2021, to respond. Answer one or answer all! Second, understand the role you play in all of this. Just because the CTA and subsequent regulations are considered "compliance", it doesn't mean other areas within your institution won't be impacted - including front line personnel who gather customer due diligence information at account opening and IT staff who ensure secure transmission of information between FinCEN and the financial institution.

For more information on the ANPRM, visit the April 5, 2021 Federal Register or access this link: https://www.govinfo.gov/content/pkg/FR-2021-04-05/pdf/2021-06922.pdf.

Authored by: Joann Lang, CIA, CAMS, CCPB

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