Bank Secrecy Act

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

A FICU must develop and administer a compliance 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:

1. Establish a system of internal controls to assure ongoing compliance

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

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

4. 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-based 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 February 02, 2023