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Bank Secrecy Act and Payments Fraud Update


Last week, the Credit Union National Association (CUNA) staff attended the Financial Crimes Enforcement Network (FinCEN)’s Bank Secrecy Act Advisory Group (BSAAG) Banking Subcommittee call to discuss the Financial

Action Task Force (FATF)’s draft recommendations on global financial system policies on anti-money laundering and counter-terrorist financing. The FATF is an inter- governmental policy-making body, which includes the U.S. and 35 other countries or regional organizations that develops and promotes such policies on the international and national levels. The call focused on financial institution concerns with the draft FATF global recommendations and its potential effects on BSA regulations and compliance in the U.S.

The Federal Reserve Bank of Atlanta recently published a blog post on payments fraud risk as financial institutions increase their adoption of remote deposit capture (RDC) on checks to additional retail and mobile payment channels. According to FinCEN, the current filing rates on RDC- related Suspicious Activity Reports (SARs) are similar to filing rates on SARs for traditional paper check depositing channels for fraud, such as check kiting and counterfeit checks.

The 2010 Federal Reserve Payments study showed that approximately 13 percent of checks are deposited as images at the financial institution of first deposit. With regard to commercial RDC, about 75 percent of U.S. banks and 50 percent of U.S. financial institutions currently offer at least one RDC service.