Are You In Compliance With the Bank Secrecy Act?
By Rick Lange
Credit Union Advisor, 2006 Spring
Examiners were provided with a more standardized approach to conducting BSA/AML examinations through the publication of the FFIEC BSA/AML Examination Manual. Due to this and the heightened awareness of money laundering activities, examiners are more focused on credit union compliance with the BSA. The following are a summary of the items which should be performed to ensure compliance with the BSA:
- Complete a risk assessment of the credit union’s exposure to money laundering activities.
- Prepare a written BSA compliance program which includes a policy to comprehensively acknowledge BSA/AML regulatory requirements.
- Design and review the BSA policy in conjunction with the board of directors.
- The credit union should appoint a BSA officer; ongoing training and education of this individual and all individuals involved with BSA within the credit union is imperative.
- Perform an independent review of the compliance program.
- Perform ongoing internal assessment process throughout the year.