Bank Secrecy Act

Examiners review a credit union’s AML/CFT program and compliance with BSA requirements during every FICU examination. For more information on the NCUA’s BSA review supervision policies, see the BSA Supervision section of the NSPM.

A FICU must develop and administer an AML/CFT program that meets BSA recordkeeping and reporting requirements. NCUA regulation § 748.2(b)(1), Program requirement, states that a FICU’s compliance program must have a written policy and this policy must be approved by the board of directors and reflected in their meeting minutes. Per NCUA regulation § 748.2(c), Contents of compliance program, the compliance program must:

• Establish a system of internal controls to ensure ongoing compliance

• Provide for independent compliance testing by credit union personnel or outside parties

• Designate an individual responsible for coordinating and monitoring day-to-day compliance

• Provide training for appropriate personnel

Examiners take a risk-focused approach to reviewing BSA compliance, based on the ML/TF risks within the credit union’s products, services, FOM, and geographic locations. This section provides high-level guidance for examiners. For more information, including risk-focused testing procedures, see the FFIEC BSA/AML Examination Manual.

This section of the Examiner’s Guide addresses the following topics:

• Primary Risks

• Risk Management

• Exam Procedures

• Workpapers and Resources

Last updated on August 19, 2024