2021 brings many BSA issues that can keep you up at night!  

The National Defense Authorization Act has a section on BSA.  The bill does not change beneficial ownership requirements for a bank, but it calls for the building of a database on the federal level.  There are other studies authorized to change CTR and SAR thresholds.  Take a first look at this bill with us during this BSA update.

From COVID Crimes and SARs to planning your Hemp policy, there are many twists and turns for 2021.  This program brings many “Have you thought about it?” items on your list of things to do for 2021.  COVID has changed customer transactions in ways we are just beginning to understand.   What will it do to your risk assessment, your exemptions, your Customer Identification Program and beneficial ownership?  Its time to begin to think about the long-term impact on your program and the short-term compliance issues.

Program Highlights:

--National Defense Authorization Act--Implications for Beneficial Ownership, CTRs and SARS

-SARs and COVID

-Transaction Monitoring gone awry--not sure anybody's baseline will be normal

-CTRs new rules still creating havoc

-CTR Phase II Exemptions—will there be any?

-Common Errors on Beneficial Ownership

-Hemp Rules and Plans approved in many states

-OFAC—New administration may bring changes in sanctions

-Red Flags for PPP Fraud

-Online account opening

-And much more