bank secrecy act / anti- money laundering (bsa/aml) compliance

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Compliance Program• Directors are responsible for ensuring that theircredit unions have a written BSA <strong>compliance</strong>program that is tailored to its level of risk– Written policies, procedures and processes• Must be written, approved by the board ofdirectors and noted in the board minutes
Compliance Program• Made up of the following:– Risk Assessment– Internal Controls– Independent Testing– Designation of BSA/AML Compliance Officer– Training– Customer (Member) Identification Program (CIP)
Page 1 and 2: BANK SECRECY ACT / ANTI-MONEY LAUND
Page 3 and 4: BSA/AML Acronyms• BSA/AML - Bank
Page 5 and 6: BSA/AML Purpose• Purpose:- To hel
Page 7 and 8: Pre-Exam Review• Review of BSA da
Page 9: COMPLIANCE PROGRAMEvery credit unio
Page 13 and 14: Risk Assessment
Page 15 and 16: Risk Assessment - Risk Matrix• Pr
Page 17 and 18: Risk Assessment - Members• Who do
Page 19 and 20: INTERNAL CONTROLSWritten policies,
Page 21 and 22: Internal Controls• Board ultimate
Page 23 and 24: Internal Controls - MonitoringMembe
Page 25 and 26: CURRENCY TRANSACTIONREPORTSExaminer
Page 27 and 28: Internal Controls - ReportingCurren
Page 29 and 30: CTR - Entities Ineligible for Exemp
Page 31 and 32: Currency Transaction ReportsExempti
Page 33 and 34: Internal Controls - Reporting SAR
Page 35 and 36: Internal Controls - Reporting SARs
Page 37 and 38: Internal Controls - Reporting SARs
Page 39 and 40: Internal Controls - Recordkeeping
Page 41 and 42: Independent Testing• Should be co
Page 43 and 44: BSA Compliance Officer(s)• Must b
Page 45 and 46: Training• All staff whose duties
Page 47 and 48: CUSTOMER/MEMBERIDENTIFICATION PROGR
Page 49 and 50: INFORMATION SHARINGExaminer will as
Page 51 and 52: Information Sharing - 314(a) Reques
Page 53 and 54: Information Sharing - National Secu
Page 55 and 56: Penalties for BSA Violations• Ind
Page 57 and 58: OFAC• Requirements are separate a
Page 59 and 60: OFAC - Prohibited Transactions• P
Page 61 and 62:
OFAC Program (Recommended)• Risk
Page 63:
Resources• MCUL: www.mcul.org (In
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bank secrecy act / anti- money laundering (bsa/aml) compliance

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