The NAFCU compliance team sometimes receives questions regarding the role of a credit union’s officers in Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance. Let’s review some of the responsibilities of the Board of Directors and Supervisory Committee in terms of a credit union’s BSA functions:
The Written Program. Section 748.2(b) of the NCUA regulations requires a credit union to have a written BSA compliance program. According to the FFIEC’s BSA/AML Examination Manual, the “BSA/AML compliance program should be commensurate” with the credit union’s risk profile for money laundering, terrorist financing and other illicit financial activity. Importantly, the regulation requires that the BSA compliance program be approved by the credit union’s Board of Directors and reflected in the meeting minutes.
According to section 748.2(c), the board-approved policy should address the original four pillars of BSA compliance (the fifth pillar, ongoing customer due diligence, was added with FinCEN’s 2016 final rule on that topic and is not mentioned in section 748.1):
- A system of internal controls to assure ongoing compliance;
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