There’s More to BSA than SARs and CTRs
The regulation also includes recordkeeping requirements for wire transfers and monetary instruments.
The Bank Secrecy Act (BSA) is more comprehensive than many people realize.
When most of us hear “BSA,” we think about the requirements under the regulation to ﬁle Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR).
But did you know there are also recordkeeping requirements under the regulation that apply to wire transfers and monetary instruments?
● Wire transfers: When your credit union acts as an originating bank for a wire transfer of $3,000 or more, you must retain a record of:
1. The originator’s name and address;
2. The amount, date, and payment instructions received;
3. The beneﬁciary bank identiﬁcation (ID); and
4. The beneﬁciary’s name and address, or the beneﬁciary’s account number if received with the payment order, along with any payment instructions received with the payment order.
The acronym PLEASE can help staff remember all the points to check when verifying a member’s ID:
● Picture: Compare the image to the individual presenting the ID.
● Logos/holograms: These can help verify the validity of a driver’s license number.
● Expiration date: If it’s out-of-date, it’s not a valid ID.
● Age: Compare the date of birth on the ID to the age of the member presenting the ID.
● Signature: Compare the signature on the ID to the one on the transaction receipt or item presented.
● Evidence of tampering: Check for possible alterations.
Whenever your credit union serves as the beneﬁciary bank in a wire transfer, you’re required to keep a copy of each payment order received.
● Purchases of monetary instruments: Credit unions must maintain speciﬁc information about the sale or issuance of monetary instruments, when a purchase totals between $3,000 and $10,000 and is made with cash.
You must maintain this information when the purchaser has a deposit account with your credit union:
1. Name of the purchaser;
2. Date of purchase;
3. Type(s) of instrument(s) purchased;
4. Serial number(s) of each instrument(s) purchased; and
5. Dollar amount of the instrument.
Verify the purchaser’s identity through credit union records or through acceptable ID, and record the method of ID.
In the past, financial institutions were required to keep this information in a physical logbook. That’s no longer the case: You can maintain the information in any format (including electronic) that gives you access to BSA records upon an examiner or law enforcement official’s request, within a reasonable period of time.
Your credit union has the right to refuse a transaction if the purchaser can’t provide the required information at the time of purchase.
CHRIS COLLVER is senior regulatory and legislative analyst for the California and Nevada Credit Union Leagues. Contact him at 800-472-1702, ext. 6053.
This article first appeared in Front Line Newsletter.