Newsroom

April 17, 2015

April BSA Blast: Effective compliance programs

NAFCU's April BSA Blast focuses on elements of an effective compliance program and notes the importance of the relationship between anti-money laundering efforts and the "integrity of the worldwide financial system."

NAFCU Regulatory Paralegal Shari Pogach summarized findings from the Justice Department's criminal division on what an effective compliance program should look like. The list includes:

  • directors and senior managers providing strong, explicit and visible support for its corporate compliance policies;
  • people responsible for compliance having stature within the institution with the necessary funding needed for resources;
  • compliance policies that are clear and in writing; and
  • policies and practices that are occasionally reviewed to stay up to date with evolving risks and circumstances.

Also covered in this month's BSA Blast is the multi-agency Bank Secrecy Act and anti-money laundering enforcement action against Germany's Commerzbank AG and its New York Branch, and the Office of Foreign Assets Control enforcement action against PayPal Inc.

The new BSA Blast quiz in this edition focuses on OFAC compliance.