It’s No Secret – Examiners Paying Close Attention to Bank Secrecy Act



Your credit union is under greater scrutiny than ever before thanks to the Bank Secrecy Act. What does all this critical observation mean for your CU? Read on for a list of must-dos when it comes to passing muster with examiners.

As criminal and terrorist activity in the United States broadens in scope, scrutinizing Bank Secrecy Act (BSA) compliance tops the to-do list of many examiners. What does this mean for the average credit union? When it comes to BSA, there is quite simply no room for error.

Luckily, not much has changed with regard to BSA regulation in the last several years. Although FinCEN recently published its final rule on the collection of beneficial ownership information, compliance with that rule isn’t required until May 2018.

While the fundamentals remain the same, examiners are applying additional scrutiny in new and interesting ways. Affiliations with money services businesses (MSBs), for example, have become especially noteworthy to examiners. In fact, NCUA has called out MSBs as a specific focus this year.

Knowing which of your business members qualify as MSBs is a must. Do your research, ask questions of your business members and talk with your compliance specialist, because the definition of an MSB is far from black and white. Digital wallets, mobile payment systems and peer-to-peer transfer systems, for example, are all considered MSBs.

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