Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

Federal Agency Key Developments Key Interagency Statements

The federal banking agencies (FBAs), NCUA, and FinCEN have partnered on BSA/AML regulatory reform efforts. States have requested repeatedly to be included in any interagency workstreams and discussions but have been left out. Recent Interagency Statements: • Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing (Issued 12/3/18) – encourages banks to consider, evaluate, and responsibly implement innovative approaches to BSA/AML compliance. • Joint Statement on BSA Resources (Issued 10/3/18) – addresses instances in which banks may decide to enter into collaborative arrangements to share resources to manage their BSA/AML obligations • Joint Statement on Risk-Focused Bank Secrecy Act/Anti-Money Laundering Supervision (Issued 7/22/19) – intended to improve transparency into the risk-focused approach used for planning and performing BSA/AML examinations and does not establish new requirements.

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Recent CSBS Work on BSA/AML Reform Joint Meetings and Letters

• Joint Meetings with the Legislative and State Supervisory Processes Committees to discuss BSA/AML reform and to develop CSBS policy.

• CSBS Primer on BSA/AML Reform – CSBS created a comprehensive primer on BSA/AML reform highlighting the current congressional landscape, the federal regulatory agencies activities, and key observations from the SSPC and the SSPC’s BSAAdvisory Team based on an informal CSBS survey.

• CSBS Letter to the House Financial Services Committee – On May 6, CSBS sent a letter to the House Financial Services Committee on draft legislation to reform BSA/AML.

• CSBS Letters to FDIC and Federal Reserve – On May 10, CSBS sent letters to Chairman McWilliams and Chairman Powell highlighting the work states do to evaluate compliance with BSA/AML for banks and non-banks requesting involvement in the ongoing reform discussions.

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