BSA/OFAC update: Recent actions and guidance

Fall 2021 is finally here. This fall and winter could potentially see some changes to the Bank Secrecy Act (BSA) landscape, as regulations are expected to implement provisions of the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act of 2020. While we wait for those developments to be announced, let’s review some recent actions and guidance from the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC).

FinCEN Notice on Online Child Sexual Exploitation

Last week, FinCEN issued notice FIN-2021-NTC3 to “call attention to an increase in online child sexual exploitation (OCSE).”  The notice recounts that law enforcement authorities have noticed an increase in crimes related to OCSE during the COVID-19 pandemic. Additionally, “OCSE offenders are increasingly using convertible virtual currency (CVC) (some of which provide anonymity), peer-to-peer mobile applications, the darknet, and anonymization and encryption services to try to avoid detection.”

The notice provides the following instructions for filing SARs relating to OCSE:


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