The Financial Crimes Enforcement Network (FinCEN) extended the comment period for its recent convertible virtual currency (CVC) proposal as requested by CUNA and other commenters. The proposal was initially issued Dec. 23 with a 15-day comment period.

FinCEN's proposal on convertible virtual currency transactions does not provide sufficient justification or a proper notice-and-comment period, CUNA wrote Monday. It seeks to address certain AML threats posed by certain convertible virtual currency and legal tender status digital asset transactions.

CUNA supports FinCEN’s efforts to update burden estimates in order to more accurately understand the regulatory compliance costs to financial institutions and agrees that certain burdens are relevant calculating the true costs of complying with CIP regulations.

FinCEN issued advisory designed an assist U.S. individuals and businesses in efforts to combat ransomware scams and attacks, which continue to increase in size and scope, while OFAC issued an advisory on potential sanctions risks for facilitating ransomware payments. 

The Treasury’s Financial Crimes Enforcement Network issued a final rule last week amending Bank Secrecy Act/Anti-Money Laundering regulations for non-federally insured credit unions. The rule is effective Nov. 16 of this year and has a compliance date of March 15, 2021.

FinCEN set forth its approach to enforcing the rules and regulations within the Bank Secrecy Act, aiming to provide clarity and transparency to its approach when contemplating compliance or enforcement actions against institutions that violate the BSA. 

FinCEN issued an advisory July 30 to alert financial institutions to potential indicators of cybercrime and cyber-enabled crime observed during the COVID-19 pandemic. Many illicit actors are engaged in fraudulent schemes that exploit vulnerabilities created by the pandemic, according to FinCEN.

CUNA supports FinCEN updating the Paperwork Reduction Act requirements for complying with the BSA regulation that requires financial institutions to file SARs Adjustment to the PRA burden calculatio because it will lead to greater accuracy in detailing the true cost to a financial institution for filing a SAR.

FinCEN has issued an advisory on COVID-19 related impostor scams and money mule schemes. The advisory is based on FinCEN’s analysis of COVID-19-related information obtained from Bank Secrecy Act data, open source reporting and law enforcement partners

CUNA supports the FinCEN updating the Paperwork Reduction Act burden estimates from complying with a BSA requirement for financial institutions to report transactions in currency of more than $10,000 using a CTR. The proposed updates change the PRA analysis for new CTR rulemakings.