Credit union bribery is illegal.

Perhaps this is news to no one, but I was reminded of this recently when asked by a NAFCU-member whether a credit union employee could accept a monetary gift of thanks from a member.  While gifts of appreciation and other gratuities from members to credit union employees are, in most cases, innocent and well-intentioned, an employee’s receipt of such gifts can raise bribery concerns.

Code of Conduct

NCUA has an old, but still effective, Interpretive Ruling and Policy Statement (IRPS) from 1987 (See, IRPS 87-1) that provides guidance to federally insured credit unions with respect to the Bank Bribery Act. See, 18 U.S.C. §215.  Among other things, IRPS 87-1 “encourages federally-insured credit unions to adopt codes of conduct that describe the prohibitions of the bank bribery law” and recommends procedures to ensure compliance with the law.

By way of brief background, the Bank Bribery Act generally prohibits a credit union “officer, director, employee, agent, or attorney ” from seeking or accepting anything of value, with the corrupt intent to be influenced or rewarded in connection with any business or transaction of the credit union. The law also prohibits anyone from offering or giving anything of value to a credit union officer, director, employee, agent, or attorney in connection with any business or transaction of the credit union, with the intent to corruptly influence or reward that person.

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