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InfoSight Highlight – FinCEN BSA Leadership Expectations

Mon, Jun 29, 2015

Columbia, Maryland

FinCEN BSA Leadership Expectations

On August 11th, 2014, FinCEN issued an advisory regarding the expectations of leadership within financial institutions, and how organizations can better foster a culture of compliance. These recommendations are intended to compliment other previous guidance, and to be incorporated with other recommendations from regulations and examiners. Recent enforcement actions have highlighted common features of BSA/AML failures at financial institutions of all sizes, and FinCEN has provided a summary of best practices to avoid future problems.

Leadership Should Provide Adequate Human and Technological Resources

The credit union should have a dedicated BSA/AML compliance officer that responsible for coordinating and monitoring day-to-day compliance with BSA. This person should have the sufficient authority, knowledge, and training to administer the BSA/AML program. If additional resources are needed, the credit union should devote sufficient support staff to carry out the task, especially when the credit union’s risk profile indicates a higher risk for suspicious activity.

FinCEN stresses that the failure to devote appropriate resources and staff to a BSA/AML compliance function could result in other failures. Since financial institutions have staff that review alerts generated by transaction monitoring systems, devoting insufficient staff and resources may result in alerts not being properly scrutinized, due to backlog or improper identification. Credit unions should be prepared to provide sufficient resources to make sure these functions are properly handled.

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Review the information today to help your credit union remain in compliance.