OTHER CONSUMER NEWS
► CRA Asset-Size Thresholds to Increase Slightly
The asset-size thresholds used to define “small” and “intermediate small” institutions under the Community
Reinvestment Act regulations have increased slightly as of January 1, following a December 29
announcement by the federal banking agencies. Based on a 0.84 percent increase in the Consumer Price
Index, a “small” institution will be one that had assets of less than $1.226 billion as of December 31 of either
of the previous two calendar years.
An “intermediate small” institution will be one that had assets of at least $307 million as of December 31 of
both of the previous two calendar years, and less than $1.226 billion as of December 31 of either of the
previous two calendar years. Read more.
ABA PUBLISHES STAFF ANALYSIS OF RECENT FATF AML/CFT REPORT
ABA has published a members-only staff analysis of the Financial Action Task Force’s recent evaluation of the
United States’ efforts to comply with international anti-money laundering and terror financing standards. The
report, which was last issued in 2006, was based on information collected during an on-site visit during 2015.
The report noted that coordination among U.S. federal agencies, law enforcement and others has improved since
the last report in 2006. FATF added that the U.S. has been effective in its use of targeted sanctions, and pointed
to significant successes in preventing the execution of financial transactions related to terrorism and proliferation.
The report also identified several areas where improvement is needed, including the absence of comprehensive
AML/CFT obligations for certain sectors and businesses; the lack of timely access to accurate beneficial
ownership information; and a lack of uniformity in AML efforts at the state level. Read the staff analysis.
FINCEN ISSUES GUIDANCE ON CASINOS SHARING SARS WITH AFFILIATES
The Financial Crimes Enforcement Network has issued guidance for casinos on sharing Suspicious Activity
Reports with a parent of affiliates. The guidance discusses limits on disclosure, such as sharing SARs with
affiliates located outside the U.S., individuals or entities within a parent company or casino's organizational
structure who perform functions unrelated to gaming, a financial institution without an independent SAR-filing
obligation such as a check casher, or a money services business that may be co-located with a casino but is not
an affiliate of the casino. Additionally, a casino's domestic affiliate that is receiving SARs may not share the SAR
information with another affiliate.
"There also may be circumstances under which a casino, its parent or affiliate, or both would be liable for direct
or indirect disclosure of a SAR, or any information that would reveal the existence of a SAR, to any person who is
the subject of the SAR," the guidance adds. "In this regard, casinos should have policies, procedures, and
internal controls in place to ensure that the confidentiality of SARs is protected. Read the guidance. For
questions, contact the FinCEN Resource Center at FRC@fincen.gov, call (800) 767-2825, or (703) 905-3591.
OTHER BSA/AML NEWS
► FinCEN Extends FBAR Filing Deadline
FinCEN announced on December 16 that it will extend the deadline for certain filings of Form 114 (the Report
of Foreign Bank Account, or FBAR) in light of a notice of proposed rulemaking issued in March to clarify who
is exempt from filing the report under the Bank Secrecy Act. ABA and SIFMA in May filed joint comments
joint comments on the proposal. The new deadline for FBAR filing is April 15, 2018. FinCEN also announced
that it would maintain April 15 as the annual FBAR filing due date going forward. Read the announcement.