During a Bank Secrecy Act Compliance Seminar here co-hosted by CUNA and NASCUS credit unions were told many are falling short on compliance.
The program specifically addressed concerns and questions about examining and/or implementing the anti-money laundering aspects of BSA programs, and included discussions with the Financial Crimes Enforcement Network (FinCEN) and NCUA.
"It was a difficult challenge to present a program on such complex subject matter as anti-money laundering compliance for an audience with varying levels of expertise and experience," said NASCUS Vice President of Regulatory Affairs Brian Knight. "But...the speakers did a fine job of highlighting the nuances of BSA compliance, and I believe that all of the attendees will be, in many respects, ahead of the industry when the FFIEC guidance is published on June 30."
NCUA Program Officer Elizabeth Habring noted that examiners are finding that some credit unions are not conducting an appropriate level of annual testing and training, or they have not written a compliance policy.
Principal Financial Institutions Analyst Werner Paul of the Virginia Bureau of Financial Institutions reported similar findings, saying the most frequent violations included unfinished independent testing, training and customer identification programs or unstructured processes for CTR and SAR reporting.
