Inside
FinCEN Indefinitely Delays Implementation of New SAR Forms;
Banks Go Green;
The SEC's and the Federal Reserve's Regulation R;
Avoid Getting Blindsided by Section 409A;
Federal Agencies Implore Lenders to Give a Helping Hand;
Get it in Writing!
On June 30, 2005, the federal banking agencies jointly released a new Bank Secrecy Act/Anti-Money Laundering Examination Manual. Over the last two years examiners have imposed new requirements on institutions following unfavorable BSA examinations or as part of memoranda of understanding or consent orders. However, it was not always clear that the examiners would expect all institutions to implement the same procedures. The Manual clarifies that many of the requirements we have observed in consent orders and the like are now expected of all institutions.