FinCEN Announces New Outreach Program to Depository Institutions with Assets under $5 billion

In 2008, the Financial Crimes Enforcement Network (“FinCEN”) initiated an outreach effort to better understand how different financial institutions comply with FinCEN regulations (“Program”). During the first stage of the Program, FinCEN met with many of the nation’s largest depository institutions.

On October 13, 2009, FinCEN announced the expansion of the Program to include the nation’s depository institutions with assets under $5 billion (“Announcement”).

The purpose of the Program is to learn how depository institutions are complying with each of the four pillars of the Bank Secrecy Act regulatory regime: program requirements, designation of a compliance officer, training and independent audit. FinCEN has expanded the Program in order to learn the unique challenges faced by smaller-to-moderate size depository institutions and where additional guidance may be helpful.

Participation in the Program is voluntary and open to all U.S. depository institutions with assets under $5 billion. Parties interested in participating must send an email to outreach@fincen.gov with the following information:

• Name of institution
• Point of contact
• Asset size
• Geographic location
• Type of charter and
• Preference of either an on-site visit by FinCEN or a visit to FinCEN’s offices.

FinCEN will select a cross-section of no less than fifteen (15) depository institutions to ensure the Program takes place with a diverse representation of depository institutions with assets under $5 billion.