The Financial Crimes Enforcement Network’s (FinCEN) new customer due diligence (CDD) requirements for business accounts are effective May 18, 2018, and CUNA’s compliance staff has received a number of questions. A recent CompBlog post examines CDD procedures and requirements.
Bank Secrecy Act regulations do not have specific provisions for CDD requirements for non-business accounts, credit unions generally rely on the Federal Financial Institutions Examination Council’s (FFFIEC) examination manual for guidance.
The CDD guidance recommends credit unions:
According to the examination manual, a credit union’s Bank Secrecy Act/anti-money laundering (BSA/AML) program should include due diligence procedures that:
Once credit unions have identified high-risk members, it should consider obtaining specific information, including source of funds, occupation, place of employment and others.
More information can also be found in CUNA’s BSA Compliance Manual and the FFIEC’s BSA/AML Examination Manual.