Client Alert: BSA/AML Compliance during Account Rollovers

Banking & Financial Institutions Client Alerts

On September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) issued a ruling granting permanent relief under certain anti-money laundering (AML) programs for covered financial institutions.  The relief is under the authority set forth in 31 U.S.C. § 5318(a)(7) and 31 CFR § 1010.970(a) and applies to certain types of accounts that automatically roll over.

Specifically, the relief is applicable to “new” accounts originated on or after May 11, 2018 in connection with any of the following:

  1. Certificate of deposit rollovers;
  2. Certain loan renewals, modifications, and extensions, if they do not require underwriting review and approval; and
  3. Safe deposit box rental renewals.

The relief applies only to rollover or renewal of the above account types and does not apply to the AML requirements for establishment of the account at origination.

If you have questions about these revised requirements or your institution’s anti-money laundering (AML) programs in general, please do not hesitate to contact us.