FinCEN recently updated its previous guidance from March 16, 2020, providing additional information to assist financial institutions in complying with Bank Secrecy Act (BSA) obligations during the COVID-19 pandemic.
The offered guidance regarding BSA obligations are:
Compliance with BSA obligations is still crucial and FinCEN still expects financial institutions to continue following a risk-based approach, and to still adhere to BSA obligations.
For beneficial ownership information collection requirements for existing customers, Paycheck Protection Program (PPP) loans for existing customers will not require re-verification under applicable BSA requirements, unless otherwise indicated by the institution’s risk-based approach to BSA compliance.
FinCEN is suspending implementation of the Feb 6, 2020 ruling on CTR filing obligations when reporting transactions involving sole proprietorships and entities operating under a DBA until further notice.
FinCEN has created a COVID-19 specific online contact mechanism for financial institutions to communicate COVID-19 related concerns while adhering to their BSA obligations. Complete FinCen's online contact form, choosing “COVID19” in the subject drop down list, to connect with the agency. Additionally, FinCEN recommends contacting your regulator or BSA examining authority as well should you have BSA compliance concerns.