Misgen discusses director BSA duties for webcast participants.
Oct. 11, 2012 – NAFCU webcast participants Wednesday got an overview of credit union directors’ responsibilities under the Bank Secrecy Act, including a look at what policies, procedures, and processes need to be in place to be compliant.
Led by compliance expert John Misgen, CPA, the webcast covered a wide-range of regulations under the BSA, USA Patriot Act and Office of Foreign Assets Control as they relate to credit unions.
The credit union board, acting through senior management, is ultimately responsible for ensuring an effective BSA/anti-money laundering internal control structure is in place, Misgen said. That includes suspicious activity monitoring and reporting.
The Board and senior management should be informed of any changes and new developments in the BSA, its implementing regulations and directives, and the federal banking agencies’ regulations, he said.
Other key points made by Misgen include:
- Credit unions need to designate an individual or individuals to manage BSA compliance and ensure there is adequate training;
- Credit unions’ BSA/AML compliance program must be designed around a risk assessment –– on this point, Misgen noted that business accounts typically pose more risk and therefore require additional time and resources to perform;
- SARs filings are highly confidential and are not to be shared with credit union members;
An archive of the webcast is now available.