Regulatory Compliance Updates for Banks & Credit Unions – October 2020 Recap

October brought a change of season as well as many regulatory compliance changes. We’ve rounded up some top updates that impact you and your financial institution. Continue reading to ensure you are up to date on a few of the most recent regulations.

FinCEN Advisory on Identifying and Reporting Human Trafficking and Related Activity

On October 16, 2020, FinCEN published a supplemental advisory on identifying and reporting human trafficking. The advisory discusses new, evolving techniques human traffickers use to launder money. Additionally, the advisory identifies 10 new financial red flag indicators.

Why Is This Important to Me?

With some new investigative reporting coming out, financial institutions and FinCEN are under increased scrutiny around money laundering and suspicious activity reporting. Human trafficking is one of the most profitable international crimes, with the proceeds funneling through financial institutions. It is important to ensure your employees understand not only the red flag indicators of human trafficking and your institution’s anti-money laundering procedures but also when they should be filing suspicious activity reports.

Regulatory compliance Recap September 2020

FinCEN Advisory on Unemployment Insurance Fraud During the COVID-19 Pandemic

FinCEN released this advisory on October 13, 2020. The advisory includes descriptions of COVID-19 unemployment insurance fraud, red flag indicators, and how to report suspicious activity that may involve unemployment insurance fraud. Additionally, FinCEN requests that SARs filed for this activity include the key term “COVID-19 Unemployment Insurance Fraud FIN-2020-A007” in SAR field 2, and the narrative to indicate a potential connection between the suspicious activity and the activities outlined in the advisory.

Why Is This Important to Me?

Any time there is a national emergency, such as a pandemic, bad actors will create schemes to exploit vulnerabilities created by the emergency. The pandemic has caused unemployment claims to skyrocket, and U.S. law enforcement has detected many different types of unemployment fraudulent activity. It is important that your employees are able to spot this potential illicit activity through red flags and understand how to properly write the narrative for the SAR.

Paycheck Protection Program Loans and Change of Ownership

The Small Business Administration (SBA) has issued a procedural notice on changes of ownership of a business. The notice explains what type of ownership changes are affected as well as how the PPP borrower must notify the lender of any proposed changes.

Why Is This Important to Me?

If your institution is a PPP lender, review this notice to determine what types of ownership changes are applicable and how the PPP borrower needs to notify your institution of any proposed changes.

Rachel Davis - Product Manager at OCL

About the Author

Rachel Davis

Product Manager at OnCourse Learning

Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.

Rachel Davis - Product Manager at OCL

About the Author

Rachel Davis

Product Manager at OnCourse Learning

Rachel Davis is the Product Manager of GRC and professional education for banks, credit unions, and non-bank financial services at OnCourse Learning. Rachel has worked in the financial services industry for 12 years and keeps up to date on financial industry hot topics. Rachel received her Bachelor of Arts in English Literature from Saint Louis University.

By |2020-11-03T10:25:58-06:00November 3rd, 2020|Bank, Credit Union, Financial Services|0 Comments

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