As 2019 winds down, it might not be a bad idea to review whether your credit union promotes what the Financial Crimes Enforcement Network (FinCEN) refers to as a “culture of compliance.” Although it is not a regulatory requirement to have a culture of compliance policy or program, it can play an important role in the implementation of a credit union’s compliance program. I have reported on many Bank Secrecy Act/anti-money laundering (BSA/AML) enforcement actions in NAFCU’s BSA Blast, where a consistent theme reflected that a weakness with a financial institution’s BSA/AML program indicated a poor culture of compliance, regardless of an institution’s size and business model. A weak BSA/AML program can result in civil and criminal enforcement actions as many an institution has learned the hard way.
FinCEN has issued advisory guidance, FIN-2014-A007, indicating an organization’s culture is critical to its compliance. Policies, procedures and the compliance department are not the only components integral to a credit union’s BSA/AML compliance, according to FinCEN, this goes to the very core and culture of an organization.
As outlined in the advisory, a credit union can strengthen its BSA/AML compliance culture by ensuring:
- “Its leadership is actively engaged with compliance;
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