With a May 2018 compliance date for the Treasury’s new customer due diligence (CDD) rule, credit unions may be tempted to set it aside and focus on current compliance issues. But credit unions should use this time well, according to CUNA compliance staff, because it’s never too early to determine what changes need to be made to policies, procedures and software systems.
The Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized this change to the Anti-Money Laundering/Bank Secrecy Act (AML/BSA) rules last month, which would clarify and strengthen CDD obligations of financial institutions, including credit unions.
When it comes to AML/BSA procedures, credit unions should look at updating:
According to CUNA’s compliance staff, credit unions should also begin to consider how they will: