Product Updates April 2025
The Product Updates for April 2025 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to FinCEN’s interim final rule entitled “Beneficial Ownership Information Reporting Requirement Revisions and Deadline Extension” dated 03/21/25 that narrows the existing beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) to require only entities previously defined as “foreign reporting companies” to report BOI. Under this interim final rule, entities previously defined as “domestic reporting companies” are exempted from the reporting requirements and do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN. With limited exceptions, the interim final rule does not change the existing requirement for foreign reporting companies to file BOI reports, but it extends the deadline to file initial BOI reports, and to update or correct previously filed BOI reports, to 30 days from the date of this publication to give foreign reporting companies additional time to comply. However, the interim final rule exempts foreign reporting companies from having to report the BOI of any U.S. persons who are beneficial owners of the foreign reporting company and exempts U.S. persons from having to provide such information to any foreign reporting company for which they are a beneficial owner. FinCEN is accepting comments on this interim final rule. FinCEN will assess the exemptions, as appropriate, in light of those comments and intends to issue a final rule this year.
This rule is effective upon the date of publication in the Federal Register. Written comments must be received on or before 60 days after publication in the Federal Register.
BSA Suspicious Activity Report Notices Template
The update to this product is in response to:
- FinCEN Alert FIN-2025-Alert001 entitled “FinCEN Alert on Bulk Cash Smuggling and Repatriation by Mexico-Based Transnational Criminal Organizations” dated 03/31/25 urging financial institutions to be vigilant in identifying and reporting transactions potentially related to the cross-border smuggling of bulk cash from the United States into Mexico and the repatriation of bulk cash into the U.S. and Mexican financial systems by Mexico-based transnational criminal organizations (TCOs).
- FinCEN Advisory FIN-2025-A001 entitled “FinCEN Advisory on the Financing of the Islamic State of Iraq and Syria (ISIS) and its Global Affiliates” dated 04/01/25 that assists financial institutions in identifying and reporting suspicious activity related to the financing of the Islamic State of Iraq and Syria (ISIS). ISIS is a Sunni terrorist organization that has conducted and inspired terrorist attacks worldwide for more than a decade, killing or injuring thousands of people.
As a reminder, the BSA Suspicious Activity Report Notices Template is included in the purchase price of the Bank Secrecy Act Policy Template – Comprehensive Version.
Cryptocurrency Policy Template
The update to this product is in response to FDIC FIL-7-2025 entitled “FDIC Clarifies Process for Banks to Engage in Crypto-Related Activities” dated 03/28/25 that rescinds FIL-16-2022 and provides new guidance for FDIC-supervised institutions engaging or seeking to engage in crypto-related activities.
The FIL affirms that FDIC-supervised institutions may engage in permissible activities, including activities involving new and emerging technologies such as crypto-assets and digital assets, provided they adequately manage the associated risks. The FDIC expects that FDIC-supervised institutions conduct all activities in a safe and sound manner and consistent with all applicable laws, rules, and regulations.
The FDIC will continue to engage with the President’s Working Group on Digital Asset Markets and expects to issue further guidance in the future to provide additional clarity regarding banks’ engagement in particular crypto-related activities. In addition, the FDIC will work with the other banking agencies to replace interagency documents issued in January 2023 and February 2023 related to crypto-assets with further guidance or regulations.
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