NCUA’s latest supervisory letter (SL-18-01) addresses compliance with the new Bank Secrecy Act (BSA) customer due diligence (CDC) and beneficial ownership rules. According to the agency, once the BSA Questionnaire and consumer compliance violations citations have been added to AIRES, expected in September, field staff will begin evaluating credit union compliance with the new CDD rules.
However, the letter notes that, through the end of the year, NCUA field staff will not take exception to a credit union’s non-compliance with the new BSA standards found in the final CDD and beneficial ownership rules and will not identify any such noncompliance as a significant BSA violation, provided the credit union is “making a good faith effort to comply with the new rules.”
NCUA field staff will begin more in-depth reviews of credit unions’ BSA/Anti-money laundering (AML) policies, procedures and processes in 2019.
The letter also provides a list of additional guidance relevant to the CDD and beneficial ownership rules, including: