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FinCEN updates COVID-19 info

FinCEN has posted a notice updating its March 16, 2020 COVID-19 Notice to provide additional information to assist financial institutions in complying with their Bank Secrecy Act (BSA) obligations during the COVID-19 pandemic, and announces a direct contact mechanism for urgent COVID-19-related issues.

FinCEN recognizes financial institutions face challenges related to the COVID-19 pandemic. In addition, FinCEN is committed to promoting the success of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), including the need to facilitate expeditious disbursal of CARES Act funds. Accordingly, FinCEN will issue further information, as appropriate, as the CARES Act is implemented and questions arise.

FIN-2020-R001 implementation suspended
FinCEN has suspended implementation of its February 10, 2020, Ruling (FIN-2020-R001) on CTR filing obligations related to transactions of sole proprietorships and entities operating under a DBA name until further notice. Institutions that have already made the necessary changes to implement the Ruling need not revert to prior practice, and may report CTRs in accordance with the suspended ruling. Other institutions should continue to file CTRs involving sole proprietorships and DBAs under the prior practice.

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