by Terri Luttrell, CAMS-Audit, Senior Manager of Strategy & Engagement, Banker’s Toolbox 

Government Shutdown

Government Agencies Make Adjustments During Shutdown

Over two weeks ago, the government experienced a partial shutdown, leaving many government agencies scrambling to figure out how to operate without funding. This includes three agencies that have an impact on the Bank Secrecy Act (BSA): the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Controls (OFAC) and the Office of Terrorism and Financial Intelligence (TFI). Each of these agencies must now determine what are essential aspects of the BSA and anti-money laundering initiatives they need to continue to operate and update.

Here are three key updates you need to know on how these agencies will operate during the shutdown:

  • FinCEN will not be working on regulatory guidance or rulemaking. According to the Treasury’s website, it’s normal workforce has been slashed by over 60%. They will continue to provide financial intelligence to U.S. law enforcement and intelligence agencies, but not foreign law enforcement agencies. The IT systems used to file Suspicious Activity Reports (SARs) and other filings required by the BSA will be maintained.
  • OFAC will continue to update its sanctions blacklist, including the Specially Designated Nationals List (SDN List), during the shutdown.
  • TFI will continue to monitor and disseminate intelligence reporting on anticipated or actual events to Treasury leadership and other necessary authorities. They will also implement and administer new sanctions oŒn foreign countries or targeted individuals/entities through newly issued Executive Orders (EO) as necessary. They will, however, limit IT support, handling of incoming queries through the hotline and analytic support to law enforcement agencies.

Additionally, the government will not supply any speakers for AML events during the shutdown. (If you need a speaker to fill a now-void spot, contact us. We have BSA/AML experts on staff who can speak on a wide range of topics to audiences of all sizes.)

The government shutdown is expected to continue until at least Tuesday when Congress will be back in session. For updated information on these agencies during the shutdown, visit the Treasury’s website here.

Luttrell is a seasoned AML professional with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size. Terri is currently Senior Manager of Strategy & Engagement at Banker’s Toolbox. Banker’s Toolbox is the leading enterprise risk management solution for financial institutions, offering a suite of products to help mitigate risk and streamline compliance. The Banker’s Toolbox team is a unique combination of seasoned bankers, former regulators, and information technology consultants who specialize in designing, developing, and implementing risk management solutions while providing unparalleled customer service.