BSA School

Learn the history and background of the Bank Secrecy Act, including:

- 9/11 and the USA PATRIOT Act

- Government agencies' roles concerning the BSA

- Understanding money laundering and terrorist financing

Effective BSA/AML compliance program includes these five pillars:

1. Written policies and procedures

2. A designated BSA officer

3. Independent testing

4. Adequate employee training

5. Risk-based, customer due diligence

Identification of Specific Risk Categories

­- Products and services

­- Member/customers and entities

- Geographic locations

- Analysis of specific risk categories

- Developing the BSA/AML compliance program based on the risk assessment

- Updating the risk assessment

Learn the ins and outs of launching an account, including what information must be obtained when opening an account and how to verify a member's identity. Plus, you'll hear the latest on recordkeeping and retention requirements, adequate notice, and internal controls.

 - Establishment of risk-based policies, procedures and processes concerning your credit union’s BSA/AML risk profile 

- Understanding the nature and purpose of the member relationship to develop a risk profile

- Obtaining member information to substantiate the nature and purpose of the account

- Use of risk-basis procedures to maintain and update customer information

- Conduct ongoing monitoring

- Higher risk profile members and enhanced due diligence

Fraud is rising, and "fraud prevention and detection" is a NCUA supervisory priority in 2023. You'll learn the red flags to watch out for to help detect fraud, conduct investigations, and address fraudulent transactions after they have occurred.

- Beneficial Ownership rule requirements
- What is a legal entity
- What is a beneficial owner
- Identification and verification of beneficial owners
- Recordkeeping and retention requirements
- Reliance on another financial institution

- Monitoring, detecting and reporting suspicious activities
- Regulatory requirements to file a SAR
- Safe harbor from civil liability
- Systems to identify, research and report suspicious activity
- Identifying unusual or suspicious activity
- Managing alerts
- SAR decision making

- Reporting large currency transactions
- Identity verification requirement
- Aggregating currency transactions
- Structured transactions
– CTR requirements
- Filing CTRs and record retention
- Shared branches
- Back filing

- Phase I CTR exemptions
- Phase II CTR exemptions
- Annual review
- Operating rules
- Safe harbor for failing to file
- Effect on other SAR filings or other regulatory requirements

As more states legalize cannabis production, distribution and use, credit unions are increasingly faced with the opportunities and challenges of serving this burgeoning industry. Hear the BSA compliance aspects of serving the cannabis industry, from customer due diligence through SAR filing requirements.

According to FinCEN, ransomware has risen in recent years. Learn how ransomware works, current trends in ransomware behavior, and how credit unions can detect and respond.

- Section 314 of the USA PATRIOT Act information requests
- Information sharing between law enforcement and financial institutions – (section 314(a) of 31 CFR 1010.520)
- Voluntary information sharing – (section 314(b) of 31 CFR 1010.540)
- SAR supporting information 

- What is OFAC (history and background)

- Blocked and prohibited transactions

- OFAC licenses

- Reporting

- Compliance program     

- A Framework for OFAC Compliance Commitments

- Internal controls

- Independent testing

- Designated responsible individual

- Training

- Purchase and sale of monetary instruments recordkeeping

- Recording of information required for the purchase and sale of monetary instruments for currency in amounts between $3,000 and $10,000

- Funds transfers recordkeeping

- Originator financial institution responsibilities

- Beneficiary financial institution responsibilities

- Money laundering risks for funds transfer activities

- BSA record retention requirements

After enriching themselves at the expense of their governments and communities, corrupt foreign officials will sometimes turn to the U.S. financial system to launder the proceeds of their corruption. Hear the recent guidance regarding corrupt foreign officials – including FinCEN's guidance regarding kleptocracy and Russian oligarchs – and how that topic relates to BSA compliance requirements for "politically exposed persons" (PEPs).