By Jason Skemp
Worry over a credit union’s Bank Secrecy Act (BSA) program can keep management up at night. Regulations that are “not so black and white” combined with hefty penalties and the need to rely on every employee to ensure compliance makes a difficult task even more daunting. How do you know if you are reporting the transactions that need reporting? Are you doing too little or too much? We found one area of confusion came up quite often while conducting independent BSA tests: How should CUs monitor, report and document suspicious activity?
A good suspicious activity-monitoring program starts with a solid SAR (suspicious activity report) escalation process and the process varies considerably depending on the size and complexity of the credit union. Evaluating your credit union’s complexity and BSA risk is a good place to begin the process.