Compliance Blog

Written by Shari R. Pogach, Regulatory Paralegal

I simply love it when banks provide me with material when it comes time to write the BSA Blast.  In NAFCU’s April 2013 BSA Blast we have the example of TCF National Bank (TCF) in Sioux Falls, South Dakota being so off the mark with their BSA compliance practices they were slapped with a $10 million civil money penalty.  A review of account and transaction activity from November 2008 through July 2010 resulted in TCF’s late filing of 2,357 Suspicious Activity Reports (SARs) describing suspicious activity with transactions of $70 million.  TCF’s Board and management were ordered to take specific action and revamp the bank’s BSA compliance program. 

The April 2013 issue of the BSA Blast is now available for NAFCU members.  In addition to TCF’s BSA compliance deficiencies we highlight FinCEN’s list of prohibited words when completing the electronic Suspicious Activity Reports (FinCEN SARs) and Currency Transaction Reports (FinCEN CTRs). 

We’ve also made a change to the BSA Blast format with this latest issue.  It’s called the BSA Beat where we cover BSA news of note. 

And, of course, the second of the “Best of NAFCU’s BSA Blast Quizzes” is part of this issue.  These updated 25 questions with the associated answer key should make a useful training tool for both new and experienced credit union staffers.

For those of you who have taken the quizzes, I often wonder if you’ve caught on to the rather unusual sounding names that are featured in the questions.  If they sound familiar, that’s because they are:  I love movies and make references to them in my questions.  And, I try not to use the lead character names so as not to make it obvious.  Just a little trivia extra, I hope you enjoy!

Note:   If your credit union is a NAFCU-member and you'd like to receive an email update when the BSA Blast is available each quarter, just send us an email.