FinCEN News
FinCEN has been busy lately. Here are two items of interest.
- Sigue Corporation and Sigue, LLC, a money services business, was drilled with a $15 million civil money penalty. Read about it here. Read the FinCEN "Assessment of Civil Money Penalty" here.  The latter is a good read for BSA officers, in that it highlights what not to do. In addition, it shows that FinCEN just doesn't pick on banks and credit unions. Their reach is far, and they expect all to comply. The FinCEN assessment might also be useful for training purposes. There's nothing like a $15 million dollar penalty to get someone's attention.
- FinCEN has also issued FinCEN ruling FIN-2008-R001. (Wow, that numbering system seems to infer that they may produce more than one hundred rulings in a year. Sorry for that random thought.) The guidance clarifies requirements for depository institutions (which includes us) when completing a CTR on sole proprietorships and other legal entities doing business under a "DBA." Read all about it here. Â