April 08, 2014

Bahhur, Clair discuss BSA guidelines

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 Network.

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.