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Bank Secrecy Act

MD|DC CUA features qualified individuals available to assist you with your credit union's BSA program. We offer assistance to our affiliated credit unions in the following areas:


Qualified staff is available to provide the required annual BSA/AML training for the credit union's staff, board, and volunteers.

BSA Review and Testing

Qualified staff is available to conduct your credit union's required annual BSA Review and Program Testing. The components of the BSA Review and Testing include but are not limited to:

  • An evaluation of the overall integrity and effectiveness of the BSA/AML compliance program, including policies, procedures and processes.
  • A review of the Member Identification Program (MIP) to verify the credit union's adherence to proper identification and Office of Foreign Assets Control (OFAC) requirements.
  • A review of the credit union's risk assessment for reasonableness given the institution's risk profile (products, services, members, and geographic locations).
  • Appropriate transaction testing to verify the credit union's adherence to the BSA record keeping and reporting requirements (such as MIP, SARs, CTRs, CTR exemptions and information sharing requests).
  • An evaluation of management's efforts to resolve violations and deficiencies noted in previous audits and regulatory examinations, including progress in addressing outstanding supervisory actions, if applicable.A review of staff training for adequacy, accuracy, and completeness.
  • A review of the effectiveness of the suspicious activity monitoring systems (manual, automated or combination) used for BSA/AML compliance. Related reports may include suspicious activity monitoring reports, large currency aggregation, monetary instrument, funds transfer, nonsufficient funds (NSF), large balance fluctuation and account relationships.
  • An assessment of the overall process for identifying and reporting suspicious activity, including a review of filed or prepared SARs to determine the accuracy, timeliness, completeness, and effectiveness of the credit union's policy.
  • A review of filed or prepared CTRs to determine the accuracy, timeliness, completeness, and effectiveness of the credit union's policy.
  • The BSA/AML Review and Testing is currently limited to single branch credit unions, and the cost for this service is determined by the credit union's asset size.

Additional Bank Secrecy Act Resources:

Bank Secrecy Act Overview

Bank Secrecy Act Definitions

Bank Secrecy Act Checklist

Bank Secrecy Act Review Considerations

Financial Crimes Enforcement Network (FinCEN)

Federal Financial Institutions Examination Council(FFIEC)BSA/AML Examination Manual

Suspicious Activity Report


For more information contact:

Andre Lucas, Director of Compliance

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