John Zasada, Compliance Consulting Director, Financial Institutions Group

On April 3, 2020, the Financial Crimes Enforcement Network (FinCEN) issued a notice to assist financial institutions in complying with the Bank Secrecy Act (BSA) during the COVID-19 pandemic. The notice explains that financial institutions providing Paycheck Protection Program (PPP) loans to existing customers will not need to collect beneficial ownership information, unless otherwise required by their risk-based BSA program. FinCEN acknowledged it is aware BSA filings by financial institutions such as Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) might be delayed during the pandemic. FinCEN is suspending until further notice implementation of the Feb. 6, 2020 ruling (FIN-2020-R001) on CTR filing requirements when reporting transactions involving sole proprietorships and entities operating under a “doing business as” (DBA) name. FinCEN created a COVID-19-specific online contact mechanism, via a specific drop-down category, for financial institutions to communicate BSA related pandemic concerns to FinCEN. You can find it here.