Oct. 11, 2012 – Credit unions should note that the Financial Crimes Enforcement Network has made some clarifications and corrections to its electronic filing requirements for three of its Bank Secrecy Act reports.
FinCEN’s Currency Transaction Report, Suspicious Activity Report, and Form 110, Designation of Exempt Person, have all been updated to reflect clarifications in the instructions for certain fields and corrections to justifications for certain fields (right justify versus left justify, for example). Another change is that FinCEN is now including user field values from incoming records in the acknowledgement file of the reports.
The overall layout of each report file remains the same. There are no changes to field lengths or any field additions or deletions. An overview of all the changes can be seen in the revision history section at the beginning of each report file.
In addition, FinCEN recently updated its BSA electronic filing system so that users can file Form 8300 electronically. Other enhancements include greater functionality over user personal identification numbers. A complete description of all the recent enhancements can be found in the Update October 2012 document located on FinCEN’s website.
Credit unions can learn more about their BSA compliance responsibilities by viewing NAFCU’s June 27 webcast, archived and available for one year on this website. Webcast speakers included FinCEN Deputy Assistant Director Jeffrey Pratt and John Misgen, a compliance consultant with CliftonLarsonAllen LLP.