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The National Credit Union Administration (NCUA) monitors credit unions regarding the Bank Secrecy Act (31 CFR 103). A risk based approach to designing your Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) programs are the most efficient and cost effective way to ensure a well designed and compliant program. Associated Risk Group can help you with your BSA Risk Assessment.

We can assist your credit union with a written BSA Program that includes:

1. A system of internal controls including written policies and procedures to detect and prevent money laundering;
2. A designated individual to coordinate/monitor BSA compliance;
3. Conduct independent testing of the program; and
4. Train the appropriate personnel.

Our advisors can evaluate your AML Program and recommend procedures designed to detect and/or prevent money laundering activities and will address compliance with applicable anti-money laundering laws and regulations. Associated Risk Group can identify high-risk products, members, businesses, and foreign countries associated with money laundering. A customized BSA/AML risk assessment will help your credit union reduce time spent on low risk members and products while maximizing your resources on activities with higher risk and reporting requirements.

Also, a credit union is required by the USA Patriot Act §326 to have a Customer Identification Program (CIP). It is recognized that credit unions have "members" not customers; however the BSA regulations refer to this requirement as the customer identification program. A credit union may title their CIP program as the "Member Identification Program" or MIP.

The MIP must document the identification and verification of the identity of any member who opens a membership or account (12 CFR §103.121). The MIP requirements include:

1. MIP must be a part of the credit union's Anti-Money Laundering Program (AML);
2. Approved by the board;
3. Tailored to the credit union's size, location and type of business; and
4. Notice must be given by the credit union it verifies identity and why.

Credit unions are required to submit reports and/or retain records of various types of transactions and activities including:

1. Large currency transactions by its members (CTR);
2. Certain cash purchases of monetary instruments by its members;
3. Known or suspected crimes and suspicious activity reports (SAR); and
4. Certain wire (funds) transfers.

Associated Risk Group is able to share best practices developed over years of experience assist in creating and customizing a BSA/AML Program that meets your specific needs.