An adequate Bank Secrecy Act (BSA) compliance program makes life easier for everyone: credit unions and their staff, members, and NCUA, says Judy Graham, a program officer in NCUA’s Office of Examination and Insurance.
She addressed the CUNA BSA Conference in San Antonio on Tuesday.
Graham gave the 300 compliance experts in attendance an update about what the agency expects to see from credit union BSA programs during examinations.
Money services businesses (MSBs), for example, have been a particular BSA supervisory focus for the agency during the last three to four years, she says.
Not all MSBs pose the same level of risk, Graham says, which means they don’t all require the same level of due diligence.
She defined MSBs as businesses that provide one or more of these services:
Basic compliance requirements
Graham says that for basic BSA compliance programs, Part 748 of the agency's rules and regulations should be considered the minimum requirement.
Those rules say a program must:
NCUA is required by law to review BSA compliance programs during each examination of a federally insured credit union.
While regulations require credit unions to conduct staff training, they don’t establish a schedule for how often it should take place. The general rule of thumb is every 12 to 18 months, Graham says, but that depends on the credit union’s risk profile, products, and services.
Graham says NCUA’s minimum due diligence expectations include:
“Enhanced” due diligence, she adds, can include such things as onsite visits.
The CUNA BSA Conference is being held in partnership with the National Association of State Credit Union Supervisors.