VIENNA, Va. (2/24/11)--The Financial Crimes Enforcement Network (FinCEN), in a newly released report, unveiled the findings of its outreach initiative to smaller depository institutions, defined as those with less than $5 billion in assets. FinCEN’s report is the third in a series on the agency’s outreach effort and is based on information gathered from FinCEN’s individual visits and town hall-style meetings with more than 70 depository institutions including credit unions and community banks. Among its key findings, FinCEN reported that:
* Depository institutions are increasingly integrating their anti-fraud and anti-money laundering efforts. Even in cases where the two functions may not be housed in the same department, there is close collaboration on fraud and money laundering issues; * There is significant engagement with law enforcement, but many institutions do not take full advantage of existing information sharing enabled by Section 314(b) the USA PATRIOT Act to share information with their business peers; and * Institutions expressed comfort with their procedures and ability to promptly search and respond to FinCEN inquiries with respect to investigations of terrorist financing and significant money laundering.
Overall the report noted similarities between the observations of credit unions and other depository institutions that participated in the outreach events, and observations by credit unions are mentioned throughout the report. However, one unique circumstance discussed by credit unions highlighted a number of ongoing Bank Secrecy Act (BSA) compliance concerns with regard to shared branching, such as being able to track and aggregate multiple transactions at different credit unions for Currency Transaction Report purposes. Credit unions have asked that the National Credit union Administration and FinCEN provide additional guidance on BSA responsibilities in the shared branching context. Credit unions also advised FinCEN of the difficulties of expelling members that have engaged in suspicious activity that results in Suspicious Activity Report filings. Credit unions request that FinCEN and/or their regulators provide additional guidance on this issue. Use the resource link for FinCEN’s report.