Batch Validation Implementation for BSA E-Filers

Gunster – Banking and Financial Services, April 2009

Today, the Financial Crimes Enforcement Network (“FinCEN”) issued a Reminder Notice to BSA E-Filers highlighting that FinCEN will implement the second stage of its BSA Electronic Filing System (BSA EFiling)Batch Validation process at the end of July 2009. Batch Validation process currently applies field and business rules validation to Currency Transaction Reports (CTR) and Currency Transaction Reports by Casinos (CTR-C). FinCEN will begin rejecting submissions with severe data issues onJuly 31, 2009. The Reminder indicates the major rejection factors for CTRs and CTR-Cs.

Should you wish to receive further information concerning matters discussed in this publication, please contact:

Clemente L. Vazquez-Bello 305.376.6082 ▪ cvazquez-bello@gunster.com

Andres A. Fernandez 305.376.6097 ▪ afernandez@gunster.com

Marina Olman 305.376.6069 ▪ molman@gunster.com

This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken which might be influenced by this publication.

Tags: Andres A. Fernandez, Marina Olman, Clemente L. Vazquez-Bello