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 AML/CFT program, and that the approval was noted in the board minutes. When reviewing policies and procedures, examiners determine whether the AML/CFT program is tailored to the credit union’s ML/TF and other illicit financial activity risk profile, and whether the AML/CFT program includes the following requirements:

• A system of internal controls to ensure 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 (AML/CFT 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 August 19, 2024