Primary Risks

Violations of the BSA can expose credit unions to a variety of risks, specifically:

• Compliance Risk—the current and prospective risk to earnings or net worth arising from non-compliance with the BSA and any resulting civil money and criminal penalties

• Transaction Risk—the current and prospective risk to earnings or net worth arising from inadequate or failed internal processes/systems, human error, fraud, or external events such as lawsuits or penalties resulting from noncompliance with the BSA

• Strategic Risk—the current and prospective risk to earnings or net worth arising from operating policies and programs, including AML/CFT programs, that fail to support strategic initiatives

• Reputation Risk—the risk that negative publicity relating to BSA violations will adversely affect a credit union’s earnings and net worth

Last updated on August 19, 2024