Money Laundering

 The Financial Crimes Enforcement Network (FinCEN), in an effort to make the administration of the Bank Secrecy Act (BSA) more efficient and effective, published a proposal to simplify its rules and regulations by centralizing them in its own new chapter of the Code of Federal Regulations (CFR). The proposal would streamline BSA regulations into general and industry-specific parts. FinCEN said  this will allow financial institutions to identify their obligations under the BSA in a more organized and understandable manner.

FinCEN’s regulations are currently included in the CFR as Part 103 in Chapter I under “Title 31, Money and Finance: Treasury.” The FinCEN proposal would renumber its regulations into a new 10th chapter of Title 31 which would appear as “Title 31 Chapter X—Financial Crimes Enforcement Network.”

The Notice of Proposed Rulemaking as submitted to the Federal Register is available at

 FinCEN introduced enhancements to the batch validation process of the Bank Secrecy Act Electronic Filing System (BSA E-Filing) that are expected to improve BSA data quality by providing detailed error notifications to filers upon submission. This will ultimately result in more timely correction of data issues.

The process applies field and business rule validations to Currency Transaction Report, Designation of Exempt Persons, and Currency Transaction Report by Casinos records and ensures that submitted files meet the formatting requirements defined by FinCEN in the appropriate BSA E-Filing Requirements documents. In the first six months after implementation, which began on Nov. 15, FinCEN is permitting all submissions that do not correspond to formatting requirements to be accepted without warnings. After the first three months, the regulator will consider whether to extend the six-month period. After this initial grace period, the BSA E-Filing system will either accept submissions with warnings or completely reject submissions, depending on the severity of the data issue.

To allow a preview of the new functionality, FinCEN has updated the BSA EFiling User Test system, with the new batch validation enhancement, as well as provided a detailed questions-and-answers document available on the BSA EFiling Web site at


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