Q: BSA Questions. How can financial institutions raise BSA compliance concerns or challenges with FinCEN?
A: FinCEN’s April 3rd Notice stated that FinCEN had created an online contact mechanism for financial institutions to communicate to FinCEN concerns related to COVID-19. Financial institutions wishing to communicate concerns related to COVID-19 to FinCEN can:
Click on “Need Assistance,” and
Select “COVID19” in the subject drop-down list, which will facilitate COVID-19 communication with FinCEN.
FinCEN also encouraged financial institutions to contact their functional regulator(s) or other BSA examining authority as soon as practicable if a financial institution has BSA compliance concerns because of the COVID-19 pandemic. Financial institutions are encouraged to keep FinCEN and their functional regulator(s) or other BSA examining authority informed as their circumstances change.
This Q&A was contained in the Frequently Asked Questions for Financial Institutions Affected by the Coronavirus Disease 2019 (Referred to as COVID-19) – As of March 3, 2021 (which may be updated from time to time). This may be found on the FDIC’s website here: https://www.fdic.gov/Coronavirus/faq-fi.pdf.