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2009 common BSA violations highlight at CUNA conference
WASHINGTON (11/12/09)--During the recent Credit Union National Association/National Association of State Credit Union Supervisors (NASCUS) Bank Secrecy Act (BSA) conference held in San Franciso, the National Credit Union Administration (NCUA) highlighted many of the common compliance violations examiners are finding during BSA examinations. Many of these violations mirror those found in 2008. For instance, the NCUA reported that BSA training among some credit unions was not properly documented, was not comprehensive, and was not done frequently enough. The NCUA also noted that some credit unions may need to increase the frequency which with they review/update their risk assessments, as well as select anti-money laundering systems better suited to address the institution's risks. The NCUA also asked credit unions to increase the frequency and thoroughness of their independent testing. Independent testing should include transactional testing, and credit unions should use the Federal Financial Institutions Examination Council's (FFIEC) BSA/AML manual as a guide for their independent testing, the NCUA added. The NCUA said it continues to see repeated errors, such as incomplete forms and blank narratives on suspicious activity reports, and urged credit unions to utilize the BSA E-filing system. The agency also noted that the FFIEC BSA/AML Examination manual is being revised and that the revised manual should be available sometime in early 2010. The Office of Foreign Assets Control finalized its economic sanctions enforcement guidelines, which were recently published in the Federal Register with an effective date of Nov. 9. The guidelines outline the factors that will be considered in determining the appropriate enforcement response to an apparent violation of an OFAC sanctions program. This final rule supersedes all previous enforcement guidance issued by OFAC, and applies to all persons and entities subject to any of the sanctions programs administered by OFAC. The OFAC is also preparing to change its regulations to mandate electronic filing of blocked and rejected transaction reports.
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