BSA Policies & Procedures

Compliant credit unions establish appropriate policies and procedures in the following areas.

• Internal controls—NCUA regulation § 748.2(c)(1)

• Independent testing—NCUA regulation § 748.2(c)(2)

• Responsible individual—NCUA regulation § 748.2(c)(3)

• Training—NCUA regulation § 748.2(c)(4)

• CIP—NCUA regulation § 748.2(b)(2), Customer identification program

• CDD—FinCEN regulation § 1020.210(a)(2)(v)

• Beneficial ownership—FinCEN regulation § 1010.230, Beneficial ownership requirements for legal entity customers

Examiners confirm that the board of directors has written and approved the credit union’s compliance program, and that the approval was noted in the board minutes. When reviewing policies and procedures, examiners determine whether the compliance program is tailored to the credit union’s ML/TF and other illicit financial activity risk profile, and whether the compliance program includes the following requirements:

• A system of internal controls to assure ongoing compliance

• Independent testing for compliance, conducted by credit union personnel or an outside party

• Designation of an individual or individuals responsible for coordinating and monitoring day-to-day compliance (BSA compliance officer)

• Training for appropriate personnel

For more information, see the Assessing the BSA/AML Compliance Program section of the FFIEC BSA/AML Examination Manual.

Last updated on February 02, 2023