On April 1st, we alerted you to Currency Transaction Report (CTR) changes related to transactions with sole proprietorships and legal entities operating under a “doing business as” (DBA) name. These changes were set to take effect earlier this week on April 6th (September 1st for e-filing batch reporters).
On April 3rd, however, FinCEN announced that these changes would be suspended until further notice. In the meantime, financial institutions should continue to report these transactions as they do currently OR if the changes have already been implemented, they may continue to comply with the requirements in the suspended ruling.
On a side note, do not forget about BSA during these uncertain times! Although FinCEN recognizes that COVID-19 has presented many challenges, this announcement reiterated that they do expect financial institutions to continue following a risk-based approach, and to diligently adhere to their BSA obligations. In the last couple of weeks, we’ve seen that things seem to change almost daily and FinCEN stated they will provide updates, as appropriate.
We encourage you to check out the COVID-19 resources on our website. We also have a variety of BSA webinars, tailored to specific personnel, to assist you in your overall BSA compliance training efforts.
Published
2020/04/08
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