COVID-19 FinCEN Updated Guidance Summary
On March 13, 2020, the President declared a National Emergency in response to the Coronavirus Disease 2019 (COVID-19). On March 16, 2020, FinCEN issued an initial Notice encouraging Banks to communicate concerns related to the COVID-19 pandemic and to remain alert to related illicit financial activity. On April 3, 2020, FinCEN updated its March 16 Notice with additional information to help Banks comply with their BSA obligations during the pandemic, and to announce a new page on its website that Banks can use for urgent COVID-19-related issues. Finally, FinCEN indicates it will issue further guidance as the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) is implemented, including the need to quickly disburse CARES Act funds.
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