FinCEN Doubles Down on Banks’ Crypto Exposure

Taking center stage in a key-note address at the virtual 2020 ACAMS Las Vegas Conference, FinCEN Director Kenneth A. Blanco clarified a long-standing confusion banks have had regarding their exposure to cryptocurrencies and the steps they must take the mitigate these risks.  Director Blanco said that FinCEN continues to focus its efforts on a number of priority areas, including that virtual currency space stating “one issue that continues to come up during these discussions relates to mitigating risks associated with emerging payment systems, including virtual currency. To be clear, exchanges are not the only ones with crypto risk exposure. These risks are not unique to money services businesses or virtual currency exchangers; banks must be thinking about their crypto exposure as well. These are areas your examiners, and FinCEN, will ask you about when assessing the effectiveness of your AML program”.

Read the full blog here!

    Fighting the Good Fight

    Earlier this month, the Financial Crimes Enforcement Network (FinCEN) put out a cryptic statement regarding the unlawful disclosures of suspicious activity reports (SARs).   According to FinCEN, various media outlets were intending to publish a series of articles based on unlawfully disclosed SARs, as well as other sensitive government documents.  Some of you may have read the Buzzfeed article referenced by FinCEN and may have had the same reaction many of us here at 10-D Security had after reading it – mainly that, as bankers, compliance officers, and auditors, we know and understand the importance of monitoring and reporting on suspicious activity.  We know these reports are filed to support government investigations of money laundering and terrorist financing, as well as other nefarious activity – not to profit off suspect transactions or support bad actors.  We appreciate the sincere responsibility financial institutions take on a daily basis to monitor and report on suspect activity.     With that being said, we thought maybe now would be a good time to remind everyone of the numerous tips, suggestions, and guidance available on FinCEN’s website regarding SAR filings.  From “Avoiding Common Errors in SAR Filings” to “SAR FAQs” to our personal favorite, “Writing Effective SAR Narratives” – there is a treasure-trove of information available to help you perfect your SAR-filing skills just a click away at We also want to take this time to send a huge shout-out to all the Compliance Officers out there … did you know that your special day is just around the corner? September 26 is National Compliance Officer Day!!!  Can I get a woot woot?!?!!!  So, to all you compliance officers, thank you for fighting the good fight.  Your efforts are truly appreciated! 

      Free Webinar | SAR Writing - Using Purpose and Clarity to Aid Law Enforcement | Earn 1.25 CAFP & CRCM credits, 1 CFCS credit

      Tuesday, September 22, 2020
       2:00 PM ET / 1:00 PM CT

      SAR writing is easier said than done. BSA Officers often ask, “What happens to our SARs once submitted? Is anyone even reading this information? How do I alert law enforcement to COVID-19 related fraud?” In a never-ending sea of SARs filed with FinCEN each year, it is important that your SARs are noticed and read by law enforcement. Learn how to craft a SAR narrative that tells your story and captures the attention of law enforcement while maintaining regulatory requirements.

      Join this session to learn:
      • Discover the minimum requirements of information that must be in your SARs
      • How to write effective and captivating narratives for your audience: law enforcement
      • Learn the FinCEN SAR narrative requests for COVID-19 related fraud 
      • Gain confidence in meeting all SAR writing regulatory expectations
      This session is eligible for 1.25 credits CAFP & CRCM, 1 credit CFCS
       Register today

        Suspicious Activity - Red Flags

        AVP at a bank ($4.4BUSA)
        Hello. Has anyone ever come across a good summary/definition or even scholarly article explaining when "Unknown Sources of Funds" and "Rapid Movement of Funds" may be considered suspicious, and when it can be considered normal activity ? Not all unknown sources of funds are necessarily suspicious, and similarly, not all rapid movement need be suspicious. I am looking to change the mindset in my team, and would love to refer to something. 

        Thank you.