How to improve the compliance culture at your credit union

by: Suzie Higbee

When regulators talk about the root causes of the problems in a financial institution’s Bank Secrecy Act and Anti-Money Laundering programs, invariably the cause that comes out at the top of their list is a weak culture of compliance. This is a hot topic right now due do an advisory recently released by FinCEN, the Financial Crimes Enforcement Network. We have six principles to explain what a sound compliance culture is and what to do if it is lacking at your financial institution.

Regulatory agencies have found that poor BSA performance is as much about the culture of a financial institution as it is about the products, services, customers, and geographic location of the business. This document from FinCEN highlights six hallmarks of an institution with a sound compliance culture:


A successful compliance culture starts with the board and senior management actively support and understand the institution’s compliance efforts. This can include the board of directors, senior and executive management, owners, and operators. FinCEN stated, “for a BSA/AML compliance program to be effective, it should have the demonstrable support of the leadership.” To demonstrate that support, an organization’s leaders should receive periodic BSA/AML training tailored to their roles. Leaders should have a sound understanding of BSA/AML obligations and trending state so as to make informed decisions.

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