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

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Information Sharing - 314(b) Requests• Between financial institutions• An FI must notify FinCEN of its intent to engage in informationsharing, and that it has established and will maintain adequateprocedures to protect the information• A notice to share information is effective for one year• Should ensure that the other FI or association has filed itsrequired FinCEN notice• Cannot share SARs or SAR filing information– If request relates to a trans<strong>act</strong>ion subject to a SAR,disclose only the trans<strong>act</strong>ion and member informationrequested
Information Sharing – National SecurityLetters (NSLs)• Written investigative demands that may be issued bythe local Federal Bureau of Investigation (FBI) andother federal government authorities to obtainfinancial records from financial institutions• Highly confidential – examiners will not review– Policies and procedures should be in place to process andmaintain confidentiality of NSLs– SARs should not include their existence• Questions regarding NSLs should be directed tothe local FBI office
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 and 10: COMPLIANCE PROGRAMEvery credit unio
Page 11 and 12: Compliance Program• Made up of th
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: Information Sharing - 314(a) Reques
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

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

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