Quarterly BSA Enewsletter
NAFCU's BSA Blast is a NAFCU member-only quarterly enewsletter offering coverage and analysis of credit union compliance issues and industry activity concerning the Bank Secrecy Act (BSA) and Treasury's Office of Foreign Assets Control (OFAC) regulations.
The Third Quarter issue is available now!
In This Issue
Featured Articles
The Ins-and-Outs of CTRs: Senior Compliance Counsel Keith Schostag walks through the various compliance considerations for currency transaction reports (CTRs), including: when is CTR filing triggered? When is it appropriate to aggregate multiple transactions? How does CTR filing work for shared branch arrangements? And what types of customers can have their transactions exempted from CTR filings?
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OFAC Sanctions Virtual Currency Mixer, Tornado Cash: Regulatory Compliance Counsel Justin White discusses the Officer of Foreign Assets Control’s (OFAC) recent action to add Tornado Cash, a virtual currency mixer, to the specially designated nationals (SDN) list. The article also discusses FAQs published by OFAC which address this action’s implications for the financial services industry.
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BSA Pulse
In case you missed it, FinCEN has reiterated several times during the past year that credit unions should not avoid doing business with entire categories of “high risk” customers or business types, and should instead focus on the specific level of risk posed by each individual potential member.
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