Compliance: Implementation of BSA changes

March 29, 2021

CUNA’s CompBlog addresses the new provisions of the Anti-Money Laundering Act of 2020, as there will likely be much activity around the law’s implementation. National examination and supervisory priorities are expected to be established by July 1, with regulations implementing these new priorities to follow before the end of the year. 

New beneficial ownership regulations are expected before the end of the year but are expected to only describe the new beneficial ownership form that legal entities will file when incorporating with the state.

There will be additional beneficial ownership regulations in 2022, but the rules rescinding most of the current requirements that currently require credit union compliance aren’t expected out until the third round of BOR rules, which may not be until 2023.

CUNA’s compliance staff also expects to see regulations implementing a new pilot program on sharing Suspicious Activity Report (SAR) information with affiliates.

In 2021 there will be no less than 16 reviews, studies, assessments, and analysis covering a wide range of BSA-related challenges, such as:

  • Currency Transaction Report and SAR reporting, including threshold adjustments and streamlining these reports;
  • Human trafficking;
  • Trade-based money laundering;
  • Financial technology assessment;
  • Annual reporting requirements;
  • FinCEN Exchange analysis;
  • FinCEN Domestic Liaison;
  • Financial services de-risking;
  • Review of BSA/AML regulations and guidance; and
  • No-action letters