DoJ rescinds marijuana enforcement directives, could impact CUs' BSA compliance
U.S. Attorney General Jeff Sessions yesterday rescinded directives that had instructed federal prosecutors to ease marijuana enforcement in states that have legalized the substance. The change in federal drug enforcement priorities creates additional legal and compliance challenges for credit unions serving marijuana-related businesses.
Two of the rescinded directives include the Cole memos, which were issued in August 2013 and February 2014 by then-Deputy Attorney General James Cole to address enforcement in states that had legalized and regulated marijuana. Based on the Cole memos' enforcement posture, the Financial Crimes Enforcement Network (FinCEN) issued guidance to clarify Bank Secrecy Act (BSA) expectations for financial institutions providing services to marijuana-related businesses.
As FinCEN's BSA guidance depended heavily on these now-retracted enforcement directives, the legal and compliance risks associated with serving marijuana-related businesses become more uncertain.
NAFCU has resources available on its Compliance Blog and has explored the issue in its monthly Compliance Monitor newsletter to help credit unions understand the compliance risk of serving marijuana businesses. The association's compliance team will provide members with an update on the rescinded directives' implications next week.
Add to Calendar 2019-06-06 14:00:00 2019-06-06 14:00:00 BSA: The SAR Narrative Process The Suspicious Activity Report (SAR) Narrative is a crucial part of a credit union’s Bank Secrecy Act (BSA) reporting process. The narrative should provide law enforcement with key information surrounding any suspicious activity that may be occurring at your institution. In this webinar, you will learn how to write the type of narrative to entice law enforcement to move your report to the must read pile! We’ll also discuss the SAR process and provide best practices for drafting a strong narrative. Key Takeaways: Discuss how to monitor suspicious activity Review SAR Drafting Understand how to defend your narrative Learn how to defend your decision(s) not to file Purchase Now$295 Members | $395 Nonmembers (Additional $50 for CD) One registration gives your entire credit union access to the on-demand recording until June 6, 2020.Already registered? Go to the Online Training Center to view live. Who Should Attend? NAFCU Certified Bank Secrecy Officers (NCBSOs) NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Risk Managers (NCRMs) BSA Staff Compliance Staff Risk Staff Credit Union Staff Attorneys Open to all credit unions, regardless of membership or charter type! Education Credits NCCO credit information is below; recommended 1.5 CPE credits. NCRM credit information is below; recommended 1.5 CPE credits. NCBSO credit information is below; recommended 1.5 CPE credits. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Associate Director of Education, NAFCU Learning Objectives: Discuss how to monitor suspicious activity. Review SAR Drafting. Understand how to defend your narrative. Learn how to defend your decision(s) not to file. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Regulatory Ethics - Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU email@example.com America/New_York public
Credits: CPE, NCCO, NCRM, NCBSO
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