U.S. Treasury Department guidance on when banks should link accounts for regulatory reporting purposes will prompt some financial institutions to bolster their know-your-customer procedures, say compliance officers. In March, the department's Financial Crimes Enforcement Network (FinCEN) published guidance supplementing an August 2001 administrative ruling that outlined when financial institutions should file currency transaction reports (CTRs) involving transactions made across multiple accounts. While the two publications on CTR aggregation posited similar examples and criteria under which the reports must be filed, some financial institutions see the latest guidance as setting in stone new expectations, according to Richard Zack, a banking attorney...
As a deadline for the implementation of electronic Bank Secrecy Act reporting approached earlier this month, hundreds of financial institutions questioned whether they had too little time to comply with the requirements.
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