Newsroom

In a new NAFCU Compliance Blog post today, Senior Regulatory Compliance Counsel Stephanie Lyon provides credit unions with a refresher on Office of Foreign Assets Control (OFAC) requirements and how they impact compliance with the Bank Secrecy Act's (BSA) customer due diligence (CDD) and beneficial ownership provisions.

Lyon highlights a question from the NCUA's CDD and beneficial ownership examination procedures released in August that includes a reference to OFAC requirements.

"It is interesting NCUA decided to include a reference to a completely different regulatory requirement in its BSA examination guidance, especially as NCUA came out with Letter to Credit Unions 05-CU-09 that notes the differences between OFAC and BSA requirements," Lyon writes. "Nonetheless, the question of whether and how credit unions plan to use beneficial ownership information is valid for the purposes of determining OFAC compliance.

"NCUA has been delegated the authority to examine both BSA and OFAC compliance so knowing what the agency expects with relation to both sets of requirements is important for federally-insured credit unions," she adds.

Lyon goes on to detail OFAC's 50 percent rule and how it relates to the CDD rule; she also provides various NCUA and OFAC resources to help credit unions comply with supervisory expectations.

Read Lyon's full blog here.