NAFCU statement on Financial Crimes Enforcement Network (FinCEN) final rule on customer due diligence

WASHINGTON, DC (May 11, 2016) — National Association of Federal Credit Unions (NAFCU) Senior Regulatory Affairs Counsel Michael Emancipator issued the following statement in response to the Financial Crimes Enforcement Network (FinCEN) final rule. Published in the Federal Register today under the Bank Secrecy Act, the rule imposes explicit customer due diligence requirements on “covered financial institutions.” Covered financial institutions include credit unions, and they must comply with these rules by May 11, 2018.

“NAFCU and our members believe FinCEN and BSA regulations play an important role in preventing money laundering and other criminal activity,” said Emancipator. “However, the customer due diligence rule creates an additional impediment to credit unions’ ability to serve small businesses in their communities. Many credit unions will need to hire additional staff and update IT systems in response to the final rule, which will deplete resources that would be better allocated toward member services.”

NAFCU expressed its concerns to FINCEN in 2014 on this matter, citing the cost and burden already imposed on credit unions under BSA.


The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to or @NAFCU on Twitter.


Molly Safreed, (NAFCU)

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