Banking & Financial Services

The Financial Crimes Enforcement Network (“FinCEN”) has issued a proposal (“Proposal”) to require that FinCEN reports filed under the Bank Secrecy Act (“BSA”) be filed electronically starting on June 30, 2012.

 Electronic filing (“E-Filing”) of certain FinCEN reports first became available in 2002.  Since then, FinCEN has been encouraging the use of E-Filing.  Approximately 85% of FinCEN reports are currently filed electronically.  E-Filing offers a free, web-based electronic filing system that allows filers to submit reports required under BSA regulations through a secure network.

The Proposal would require that all BSA reports be filed electronically, except for Currency and Monetary Instrument Reports (“CMIRs”).  Most CMIRs are filed with the Department of Homeland Security’s Customs and Border Protection at the port of entry/exit were there are no electronic filing capabilities.

To read a complete copy of the Proposal, please 
click here.

This publication is for general information only.It is not legal advice, and legal counsel should be contacted before any action is taken which might be influenced by this publication.

Established in 1925, Gunster Yoakley is one of Florida’s oldest and largest full-service law firms.  Its substantial and diversified practice serves an extensive client base of international, national and local businesses, institutions, local governments and prominent individuals.  The firm maintains a strong presence in Florida with offices in Fort Lauderdale, Miami, Palm Beach, Stuart, Vero Beach, West Palm Beach, Jacksonville, and Tallahassee. Gunster Yoakley is home to more than 160 attorneys and 329 employees, providing counsel to clients through 18 practice groups including corporate, immigration, employment, technology and emerging companies, tax, banking and financial services,  real estate, land use and environmental, business litigation, and private wealth services.

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