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September 29, 2015
BSA actions reviewed in NAFCU webcast
Tower Federal Credit Union Vice President and BSA Compliance Officer Cathy Martin discussed recent enforcement actions and guidance from the Financial Crimes Enforcement Network, NCUA and the Office of Foreign Assets Control in relation to the Bank Secrecy Act in a NAFCU webcast on Tuesday.
In a discussion moderated by NAFCU Director of Education Devon Lyon, Martin talked about a recent FinCEN proposal that includes requirements involving customer due diligence, or CDD. Martin emphasized that the CDD requirements were not all new and highlighted strategies to comply with the requirements.
She noted that credit unions do not need to ask members what the purpose of each account is, but rather can classify accounts by considering the product type and the member's occupation, income and history of activity. "We often feel like members don't even know how to answer that question – it's not what people are thinking when they open an account," Martin said. She also emphasized the importance of ongoing monitoring of accounts for suspicious activity.
Martin and Lyon also reviewed specific cases of money laundering, including a case involving shell companies in the U.K., in a discussion of what could be learned from those instances.
The webcast will be available on-demand through NAFCU's Online Training Center for one year.
In a discussion moderated by NAFCU Director of Education Devon Lyon, Martin talked about a recent FinCEN proposal that includes requirements involving customer due diligence, or CDD. Martin emphasized that the CDD requirements were not all new and highlighted strategies to comply with the requirements.
She noted that credit unions do not need to ask members what the purpose of each account is, but rather can classify accounts by considering the product type and the member's occupation, income and history of activity. "We often feel like members don't even know how to answer that question – it's not what people are thinking when they open an account," Martin said. She also emphasized the importance of ongoing monitoring of accounts for suspicious activity.
Martin and Lyon also reviewed specific cases of money laundering, including a case involving shell companies in the U.K., in a discussion of what could be learned from those instances.
The webcast will be available on-demand through NAFCU's Online Training Center for one year.
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