SAN DIEGO - If your credit union is using your corporate to send outgoing wires, do you really have to do an OFAC check if the corporate is already doing so?
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You don’t have to, but it’s smart to do so, according to NCUA Supervisory Examiner Linda Thompson. “The reason is that you have the final responsibility, so if you put your reliance on the corporate and they miss it, then the fine still comes to the credit union.”
Added NCUA General Counsel Bob Fenner, “It’s your responsibility, as you bear the consequences of non-compliance.”
The remarks came at NAFCU’s annual meeting.(c) 2008 The Credit Union Journal and SourceMedia, Inc. All Rights Reserved.http://www.cujournal.com http://www.sourcemedia.com
