Gunster – Banking Advisory, October 2008
Today, the Financial Crimes Enforcement Network(“FinCEN”) announced its plans to release new system enhancements to the Batch Validation process (“BatchValidation Process”) of the Bank Secrecy Act Electronic Filing System (“BSA E-Filing”) onNovember 15, 2008 (“Announcement”). The goal of the Batch Validation Process enhancements is to improve BSA data quality by providing detailed error notifications to filers upon submission.
The new Batch Validation Process will apply field and business rule validations to Currency TransactionReports (“CTRs”), Designations of Exempt Persons,and CTRs by Casinos, as well as ensure that submitted files meet the formatting requirements defined byFinCEN.
The Batch Validation Process will be implemented in two (2) stages. The first stage, which will continue for a minimum of six (6) months, will permit all submissions that do not correspond to formatting requirements to be accepted with warnings. Accompanying the warning messages will be a corresponding entry in the BSA E-Filing Track Status with additional information for any file that does notadhere to the field and business rule validations.
Three (3) months after the release of the first stage, FinCEN will assess the process to determine if the initial six (6) month period should be extended. Once FinCEN initiates the second stage of the approach, the BSA E-Filing system will either accept submissions with warnings or completely reject the submission, depending on the severity of the data issue(s).
FinCEN has updated the BSA E-Filing User Test system with the new Batch Validation Process enhancements to provide a preview of the new functions and included a detailed Questions and Answers document. The preview and Questions and Answers are available on the BSA E-Filing web site: http://sdtmut.fincen.treas.gov/.
Should you wish to receive further information concerning matters discussed in this Banking Advisory,please contact Clemente Vazquez-Bello, Esq. at (305)376-6082, Andres A. Fernandez, Esq. at (305) 376-6097 or Marina Olman, Esq. at (305) 376-6069 or [email protected],[email protected] or [email protected].
This Banking Advisory 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 Banking Advisory.
