September 28, 2022

New BSA Blast covers currency transaction reports, OFAC updates, more

Consumer protectionA new edition of NAFCU’s BSA Blast is now available on the association’s website in its user-friendly digital format with direct links to each section. The BSA Blast is a NAFCU member-only, quarterly e-newsletter offering coverage and analysis of credit union compliance issues and industry activity concerning the BSA and related issues.

The third quarterly issue features articles reviewing currency transaction reports (CTRs) and the Office of Foreign Asset Control’s (OFAC) recent action to add Tornado Cash to the specifically designated nationals (SDN) list.

In the first featured article, Senior Compliance Counsel Keith Schostag lays out various compliance considerations for CTRs, detailing when a CTR filing is triggered and when it’s appropriate to aggregate multiple transactions. Schostag also notes how CTR filings work for shared branch arrangements and what types of customers can have their transactions exempted from CTR filings.

In the second featured article, Regulatory Compliance Counsel Justin White covers OFAC’s recent action to add Tornado Cash, a virtual currency mixer, to the SDN list and the FAQs published by the agency, which addresses implications on the financial services industry as a result of this action. 

This edition also includes the BSA Pulse, which covers FinCEN and NCUA’s statement issued on the “Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence.” The statement reminds credit unions to not fully avoid doing business with entire categories of “high risk” customers or business types, and instead focus on the specific level of risk posed by each individual potential member.

Access more from NAFCU's award-winning Compliance Team here.