Whether your credit union is under $5 million in assets or above $1 billion, compliance with the Bank Secrecy Act is critical. The BSA requires financial institutions, including all federally insured credit unions, to file Currency Transaction Reports, Suspicious Activity Reports and to have a written Customer (Member) Identification Program (C/MIP), among other things.
Recently, MCUL & Affiliates, along with Department of Insurance and Financial Services (formerly OFIR) met with several very small credit unions to specifically discuss the importance of compliance with the BSA, along with the recent mandate by FinCEN for financial institutions to utilize the new CTR and SAR forms and to file those forms electronically through the E-Filing System. Failure to comply may subject the financial institution to civil money penalties.
Speaking of penalties, during the past six months, there have been a few banks in the headlines being assessed civil money penalties for failure to establish, maintain and implement an adequate or effective BSA/Anti-Money Laundering program. Use this as an opportunity to review your credit union’s BSA/AML compliance program for effectiveness. Resources are available on the Bank Secrecy Act page of InfoSight, available here.