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          This effort “significantly contributes to our ability to combat   Addressing the rule’s 25 percent reporting threshold, El-Hindi
          the increasingly sophisticated money laundering efforts we   noted that regulators included language in the rule that gives
          face,” Mandelker said, noting that FinCEN Exchange builds   banks flexibility to collect additional information on customers
          on a series of a dozen pilot briefings held for 40 institutions   below the 25 percent equity interest threshold in order to
          since 2015. “It is time to institutionalize this program within   “support industry’s own efforts” when they feel they need to
          our AML framework,” she added.                         collect information at a lower threshold. Andrea Sharrin,
                                                                 director of FinCEN’s policy division, added that the agency is
          Mandelker emphasized that FinCEN Exchange is “not intended
          to add a regulatory burden to your financial institutions. We’re   finalizing a new set of frequently asked questions, and regulators
          not imposing any new requirements.” Instead, she explained,   noted that they are working to update the FFIEC manual to
          it is designed to help banks “channel resources toward high-  incorporate new information on beneficial ownership.
          priority targets.”                                     When it comes to enforcing the beneficial ownership rule,
                                                                 the OCC’s Donna Murphy noted that regulators “have been
          To read more visit:
          releases/fincen-launches-fincen-exchange-enhance-public-  planning to begin looking at compliance through the risk-based
          private-information-sharing                            examination process once the date comes into effect. If there are
                                                                 deficiencies, we will be addressing them.” She added, however,
                                                                 that “that doesn’t mean one should expect to see a plethora of
          Appraisal Board Issues                                 enforcement actions.”
          Proposal to Combat Appraiser                           Discussing enforcement more broadly, regulators noted that the
          Shortage                                               anti-money laundering violations today are much more nuanced
                                                                 than in previous years. “Nowadays, we’re seeing a much, much
          As lenders continue to raise concerns about a lack of   higher level of compliance,” said Sarah Green, senior director
          certified appraisers, particularly in rural areas, the Appraisal   for enforcement and AML policy at FINRA. “Violations are
          Qualifications Board (AQB) has released a fourth exposure   generally more focused on specialized instances.”
          draft of a proposal to change the qualification criteria for real
          property appraisers. The AQB proposed to remove college degree
          requirements for licensed residential appraisers and provide
          alternatives to the bachelor’s degree requirement for certified
          residential appraisers. The proposal also outlines an alternative
          track for licensed residential appraisers to become certified
          without  obtaining  a  bachelor’s  degree.  In  addition,  it  would
          reduce the number of field hours needed from 2,000 to 1,000 for
          licensed appraisers and 2,500 to 1,500 for certified appraisers.   When you need experience now!
          Comments are due January 12.
                                                                     We Can Help Your Financial Insstuson With...
          To view the proposal visit: https://appraisalfoundation.

          FinCEN Considering Further

          Guidance on Beneficial
          Ownership Rule                                          Vendor Contract   Payment System     On-Demand
                                                                   Negotiations        Options         CIO Services
          As the banking industry prepares to implement the Financial
          Crimes Enforcement Network’s final beneficial ownership
          rule, FinCEN Acting Director Jamal El-Hindi said that the
          agency is considering additional guidance to help address
          lingering questions from financial institutions ahead of the May
          2018 compliance deadline. The rule requires banks to collect       Technology      Core Application
          information on beneficial owners – individuals who own more         Planning           Review
          than 25 percent of the equity interests in a company, or a single
          individual who exercises control – when an account is opened.

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