Newsroom

The July issue of NAFCU's BSA Blast enewsletter offers an overview of the Financial Crimes Enforcement Network's final rule on Bank Secrecy Act customer due diligence requirements for credit unions and a look at a recent BSA enforcement action.

NAFCU Regulatory Paralegal Shari Pogach explained the four components of the customer due diligence requirements, which are now a part of credit unions' BSA/anti-money laundering compliance obligations. Those components address identification and verification of customers and of beneficial owners of accounts, nature and purpose of customer relationships and ongoing monitoring.

"The first CDD component (establishing and verifying a customer's identity) already was an AML requirement," Pogach notes. "And, although the third and fourth components (understanding the nature/purpose of customer relationships and ongoing monitoring) were implicit under the existing AML rules, the new rule makes these clear requirements of any BSA/AML compliance program."

The Blast also includes a quiz covering aspects of the CDD rule.

Last week, FinCEN published a "frequently asked questions" document to help financial institutions determine how they are affected by the final rule, which was issued in May.

Pogach also detailed a recent FinCEN civil money penalty assessment of $2.8 billion against a "card club" gaming entity based in Hawaiian Gardens, Calif., for repeated violations of the BSA and its reporting requirements.

In related news, some registration openings still remain at NAFCU's inaugural BSA Seminar, set for Oct. 24-28 in New Orleans. Registrants can earn a NAFCU Certified Bank Secrecy Officer (NCBSO) designation by taking and passing an optional exam after the seminar. Early-bird registration savings are available until Sept. 9.