Alert March 08, 2011

Banking Agencies Issue Advisory Concerning FinCEN’s Reorganization of BSA Regulations

The FRB, FDIC, OCC, OTS, NCUA and the State Liaison Committee issued a Joint Advisory (the “Advisory”) notifying financial institutions that the Financial Crimes Enforcement Network (“FinCEN”) had issued a final rule reorganizing and transferring FinCEN’s Bank Secrecy Act (“BSA”) regulations to a new chapter in the Code of Federal Regulations.  FinCEN’s regulations now appear in a new chapter entitled “Title 31, Chapter X—Financial Crimes Enforcement Network.”  The new chapter generally organizes regulations by industry and indicates those provisions that are applicable to all regulated industries or covered individuals.  The Advisory states that the new chapter does not change existing BSA regulatory obligations or impose new obligations.  The effective date of the reorganization was March 1, 2011.