Bank Secrecy Act

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Bank Secrecy Act

Compliance Couriers

Agencies: Assess members’ CDD risks individually

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BOI rules going back into effect

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FinCEN asks for suggestions to modernize BSA rules

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FinCEN eases beneficial ownership verification at each new account opening

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FinCEN issues interim final rule removing BOI reporting requirements for U.S. companies and persons

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FinCEN proposes to update anti-money laundering rules

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Former Credit Union BSA Compliance Officer fined 100,000.

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Include “non-critical” information when completing SARs & CTRs

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Is your credit union on the lookout for human trafficking?

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League comments on FinCEN’s AML/CFT proposal; similar NCUA proposal pending

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NCUA & other federal regulators want feedback on AML/CFT proposals

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NCUA hosting BSA webinar Aug. 24

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NCUA’s 2026 Supervisory Priorities

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NCUA’s 2024 Supervisory Priorities

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Section 314(b): To Share or Not to Share

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Serving higher-risk businesses requires enhanced due diligence

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Take care when preparing CTRs for deposits into joint accounts

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Federal Regulations

NCUA: 12 CFR 748.2

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TREAS: 31 CFR 1010 (Chapter X)

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ii Releases

0071 Bank Secrecy Act

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0109 BSA: Suspicious Activity Reports

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0155 NCUA Guidelines for Safeguarding Member Information, Responding to Unauthorized Access, and Reporting Cyber Incidents

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0159 BSA: Customer Identification Program and Customer Due Diligence

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0187 BSA: Money Services Businesses

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Resources

America’s Credit Unions: e-Guide – Bank Secrecy Act (BSA)

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FFIEC: Bank Secrecy Act Anti-Money Laundering Examination Manual 2014

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FFIEC: Money Laundering Red Flags

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FinCEN: BSA Regulatory Overview, including BSA Forms and Filing Information

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FinCEN: FIN-2009-G003 – Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting (August 31, 2009)

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FinCEN: FIN-2010-G004 – Funds “Travel” Regulations: Questions & Answers (November 9, 2010)

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FinCEN: FinCENs 314(a) Fact Sheet (6/16/2020)

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FinCEN: Frequently Asked Questions Regarding the FinCEN Currency Transaction Report (CTR)

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FinCEN: Frequently Asked Questions Regarding the FinCEN Suspicious Activity Report (SAR)

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FinCEN: Interagency Interpretive Guidance on Providing Banking Services to Money Services Businesses Operating in the United States (April 26, 2005)

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FRB: Interagency Statement on Sharing Bank Secrecy Act Resources (October 3, 2018)

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OCC: Money Laundering: A Banker’s Guide to Avoiding Problems (December 2002), 35 pp.

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Other

#81080 – Customer Identification Card (Rev. 5/15)

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BSA Risk Assessment Matrix (9/11)

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The League’s Customer Identification Program Poster (07/21/03)

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