The COVID Project
Context, not an orderThis record is guidance or an announcement kept for context. It is not counted among the orders in force.
The record
- Jurisdiction
- United States; Financial Crimes Enforcement Network, Department of the Treasury (federal)
- Level
- Federal
- Authority
- 31 U.S.C. § 5318; 31 C.F.R. § 1010.810
- Issued
- 2020-04-03 Apr. 3, 2020
- Effective
- 2020-04-03
- End
- Not rescinded within the period (read as 2021-09-30)
- In force
- Apr. 3, 2020 to Sept. 30, 2021
- Quarters
- 2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
- Limitation types
- Other
- Addressees
- all financial institutions subject to the Bank Secrecy Act
- Functions reached
- OP compliance (BSA reporting timelines; remote compliance staff)
- HR
- CB customer due diligence under PPP volume
- Character
- context
- Collection
- Federal financial regulators AGY-FED-FINANCIAL
Operative words
This notice updates the Financial Crimes Enforcement Network's (FinCEN's) March 16, 2020 COVID-19 Notice, provides 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.
Enforcement
31 U.S.C. §§ 5321-5322 (civil and criminal BSA penalties); FinCEN stated it would consider pandemic-related delays
Notes
Records FinCEN's recognition that compliance staff were working remotely and that filing delays were pandemic-driven; also addresses Beneficial Ownership rules for PPP loans
Retrieval noteRendered from the April 3, 2020 Wayback capture; file originally saved with the March 16 date and renamed to the verified April 3, 2020 release date. Cite it as context and cite the underlying order, statute or emergency rule it describes as the instrument. (Bulletins whose operative text imposes a mandatory duty on licensees under the regulator's own authority are excluded from this downgrade and listed separately for review.)).