Product Updates for October 2022
The Product Updates for October 2022 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 Final Rule entitled “Beneficial Ownership Information Reporting Requirements” dated 09/30/22 that requires certain entities to file with FinCEN reports that identify two categories of individuals: the beneficial owners of the entity, and individuals who have filed an application with specified governmental authorities to create the entity or register it to do business. These regulations implement Section 6403 of the Corporate Transparency Act (CTA), enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021 (NDAA), and describe who must file a report, what information must be provided, and when a report is due. In addition, these requirements are intended to help prevent and combat money laundering, terrorist financing, corruption, tax fraud, and other illicit activity, while minimizing the burden on entities doing business in the United States. The final rule is effective January 1, 2024.
Bank Secrecy Act Policy Template – Comprehensive Version
Office of Foreign Assets Control Policy Template
The update to these products is in response to OFAC’s Compliance Communique entitled “Sanctions Compliance Guidance for Instant Payment Systems” dated 09/30/22 that emphasizes the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems and to highlight considerations relevant to managing those risks. In addition, this guidance encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.
Bank Secrecy Act Policy Template – Comprehensive Version
Office of Foreign Assets Control Policy Template
The update to these products is in response to OFAC’s “Amendment to the Cyber-Related Sanctions Regulations and Associated Administrative List Updates” dated 09/02/22 that amends, and reissues in their entirety, the Cyber-Related Sanctions Regulations, 31 C.F.R part 578. This administrative action replaces the regulations that were published in abbreviated form on December 31, 2015, with a more comprehensive set of regulations that includes additional interpretive and definitional guidance, general licenses, and other regulatory provisions that will provide further guidance to the public. The Cyber-Related Sanctions Regulations are effective when they were published in the Federal Register on Tuesday September 6, 2022.
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