Newsroom

October 19, 2018

Resource sharing, CDD relief detailed in BSA Blast

bsa blastThe newest edition of NAFCU's BSA Blastnow available for download – details important changes related to Bank Secrecy Act (BSA) compliance, including the recent statement from federal depository institution regulators on how to share BSA/anti-money laundering (AML) resources and permanent exceptive relief under the customer due diligence (CDD) rule.

The BSA Blast is a NAFCU member-only quarterly enewsletter offering coverage and analysis of credit union compliance issues and industry activity concerning the BSA and related issues.

On sharing BSA/AML resources, NAFCU Regulatory Paralegal Shari Pogach writes that such arrangements "are generally more suitable for institutions with a community focus, less complex operations and lower-risk profiles for money laundering or terrorist financing." Pogach notes that the collaborative arrangements can "increase operational efficiencies and better utilize specialized expertise," and goes on to explain the components, including internal controls, risk mitigation and training.

In another article, Pogach recaps remarks made by Financial Crimes Enforcement Network (FinCEN) Director Kenneth Blanco on how the agency uses BSA information it collects. Of note, FinCEN receives nearly 1,900 suspicious activity reports (SARs) related to terrorist financing each year, and roughly a quarter of the terrorism cases FinCEN has reviewed had BSA reporting before a person's arrest.

The final article explains CDD's permanent exemption related to beneficial ownership requirements. Pogach says the exemption "applies when a legal entity member opens a new account due to the rollover, renewal, modification and extension of certain accounts," of which she provides descriptions.

This issue of the BSA Blast also includes a Q&A forum, with questions and answers on determining the beneficial owner of an incorporated non-profit and reporting time periods for filing multiple SARs.

Relatedly, the Federal Financial Institutions Examination Council (FFIEC) launched a redesigned BSA/AML InfoBase website this week to improve user experience as financial institutions and others seek examination resources.