From the desk of Leah Walton

Understanding the 2009 CTR Exemption Rule

  FinCEN recently released feedback regarding the 2009 CTR Exemption Rule which took effect on January 5, 2009. The purpose of this amendment is to simplify the Designation of Exempt Persons (DOEP) process which in turn will reduce the number of CTRs filed. So has this rule assisted in reducing the amount of CTRs filed? […]

SAR Activity Review – Trends, Tips & Issues

The newest edition of this Bi-annual report generated from FINCEN  is now available. Issue 16 gives a detailed summary of the following: Mortgage loan fraud Trends and benefits of BSA E-Filing system Analysis of SAR inquiries Law enforcement cases Suggestions for filing a SAR What’s new for auditing the AML program This issue’s Law Enforcement […]

Non-Member OFAC Scans….What do you think?

How do you prove that Non-Members are included in the CU*BASE OFAC scan? This question keeps popping up and I believe we need to find a better solution.   When an OFAC scan is run it does include non-members. If there is a match it will show up on the printable OFAC Data Match report. […]

What’s Showing up in BSA?

As we are ending February, we are entering into prime time tax refund season. The activity on the Bank Secrecy Act report has soared due to these transactions. Although they may seem like an expected transaction for this time of year, it doesn’t mean they are all legitimate.   When the tax refund posts to an […]