Removing Barriers Blog

NCUA Issues Supervisory Letter re: BSA/AML Compliance
Posted August 27, 2018 by CUNA Advocacy

NCUA issued Supervisory Letter 18-01, outlining examination expectations regarding Bank Secrecy Act and Anti-Money Laundering compliance. NCUA’s updated BSA examination questionnaire is expected to be included in the September AIRES release, with examinations including the updated compliance violation schedule commencing subsequent. The letter notes that credit unions making good faith efforts to effectively comply the FinCEN’s May 11, 2018 Customer Due Diligence rule shall not be subject to compliance violations for infractions thereto.

Under FIN-2018-R001, exceptive relief from the CDD rule is provided for covered financial institutions to collect and verify the beneficial owner of a legal entity customer opening a premium financing account where there is potential for a cash refund. FinCEN also provided limited relief from the beneficial ownership requirements for automatic roll-over and renewal products established prior to May 11, 2018 (until September 16, 2018).