The NCUA and other Federal
financial regulators issued a joint fact sheet regarding compliance
efforts required to meet Bank Secrecy Act (BSA) due
diligence requirements for customers that are charities and other
nonprofit organizations.
In the joint
statement, the agencies stated that the due diligence efforts should be
based on the money laundering risks posed by the customer relationship.
The clarification was issued to recognize that legitimate charities and
nonprofits deserve and benefit from access to financial services, and “do not
present a uniform or unacceptably high risk of being used or exploited for
money laundering, terrorist financing, or sanctions violations . .
..” Accordingly, the due diligence expected of credit unions and other
banks should be based on the risk profile of individual charitable
customers, and the fact sheet gives examples of useful customer data that
credit unions may want to collect to help determine those risks.
The fact sheet was developed and disseminated by
the National Credit Union Administration, the Federal Reserve Board,
the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement
Network, and the Office of the Comptroller of the Currency.