April 9, 2014- Credit
unions that tuned into NAFCU’s webcast yesterday were
provided with an overview of the latest Bank Secrecy Act guidelines, specific
case studies and suggestions on how to ensure compliance.
JiJi Bahhur, NAFCU’s director of regulatory compliance,
talked about the rise of virtual currencies, specifically Bitcoin, and made
clear that “there is not a central authority; Bitcoin is powered by its users.”
Bahhur said virtual currency users are not subject to BSA regulatory
requirements, according to guidance from the Financial Crimes Enforcement
Bahhur also spoke about monetary and risk issues featured in
NCUA’s 2014 supervisory focus in Letter to CUs 14-CU-02 and BSA-related requirements.
Bernadette Clair, NAFCU’s senior regulatory compliance
counsel, highlighted marijuana business laws under the Department of Justice’s
“Cole memo” and FinCEN guidance. She reiterated that the credit union must
decide whether to serve such businesses. “The decision to open this type of
account is a risk-based decision for a credit union,” said Clair.
She also discussed case studies of financial institutions’ BSA
procedures and how other credit unions can apply these to their own situations.
The webcast, “BSA Case Studies: Lessons to Enhance Your Program,” is available through NAFCU’s Compliance Webcast and Online Training Subscription.