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BSA/AML enforcement statement issued by federal agencies
Federal banking agencies, including the NCUA and Federal Reserve, issued an interagency statement to update their existing guidance on enforcement of required Bank Secrecy Act (BSA)/anti-money laundering (AML) obligations. The statement does not create new expectations or standards; however, it clarifies that isolated or technical violations generally do not result in an enforcement action and addresses how the agencies evaluate violations of individual components (pillars) of the BSA/AML compliance program.
In the statement, the agencies – which also includes the FDIC and the Office of the Comptroller of the Currency (OCC) – described how they will incorporate the customer due diligence regulations and recordkeeping requirements issued by the Treasury Department as part of the internal controls pillar of the financial institution’s BSA/AML compliance program when evaluating.
BSA/AML compliance is one of the NCUA’s 2020 supervisory priorities; the agency recently revised its supervisory priorities in light of the coronavirus pandemic. In addition, BSA/AML reform is one of NAFCU's advocacy priorities for 2020, and the association previously urged the Senate to advance BSA/AML legislation as the House last year passed NAFCU-supported legislation to reduce the burden of suspicious activity report (SAR) and currency transaction report (CTR) filings.
View NAFCU's resources on BSA/AML, including a webinar and previous blog posts (here and here), to help credit unions comply with the customer due diligence rule.