Responsible Individual (AML/CFT Officer)

Under NCUA regulation § 748.2(c)(3), FICUs are required to designate an individual responsible for coordinating and monitoring day-to-day BSA compliance. This individual is generally referred to as the AML/CFT officer or BSA compliance officer. The board of directors ensures the AML/CFT officer has the knowledge, authority, independence, and resources to fulfill the responsibilities of this position.

In smaller credit unions, the AML/CFT officer is likely the credit union manager or assistant manager. In larger credit unions, the AML/CFT officer is generally the manager of the BSA or compliance department. Scheduling an entrance meeting with the AML/CFT officer will help the examiner gain an early understanding of the credit union's AML/CFT program.

Examiners verify that the credit union’s board of directors has designated an individual responsible for the overall AML/CFT program and that the individual is qualified. Examiners review reports to the board of directors and senior management regarding the status of ongoing compliance and pertinent BSA-related information, including the required notification of SAR filings. Examiners confirm the AML/CFT compliance officer has the authority, independence, and access to resources.

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

Last updated on August 19, 2024