Mon, Nov 2, 2015
Q. Do credit unions need to have two separate policies, one for OFAC regulations and another for the Bank Secrecy Act?
A. According to NCUA Letter to Credit Unions 01-CU-25, a credit union must have policies and procedures in place for the purpose of complying with OFAC regulations and the various laws that OFAC is responsible for administering. However, the Letter does not indicate that there is any prohibition from combining it with the BSA policy. Therefore it appears that the credit union may incorporate the OFAC policy into your BSA policy, provided that the current BSA policy is in compliance with Part 748 of NCUA Rules and Regulations.
Q. Does the credit union need to file an OFAC Annual Report of Blocked Property if it has had no hits on the SDN List in the last year?
A. There is no need to file the report if there were no hits on the SDN List in the last year and the credit union is not holding any blocked property.