ALEXANDRIA, Va.–NCUA’s Office of Inspector General (OIG) has made four recommendations to improve the agency’s Bank Secrecy Act (BSA) program.
According to a new report from the OIG, NCUA has been making progress in the five areas the OIG selected for review, but there are additional improvements that can also be made.
The OIG said NCUA has agreed with its OIG’s recommendations, which are based on an audit that included federal credit union BSA examinations and enforcement actions from Jan. 1, 2018, through Dec. 31, 2021.
The Recommendations
The OIG is recommending NCUA:
- Update the BSA scope tasks and questions within the Modern Examination and Risk Identification Tool (MERIT) to ensure examiners complete and document all necessary steps during BSA examinations. This includes directing examiners to use additional external guidance such as the National Supervision Policy Manual (NSPM), Examiner’s Guide, and Federal Financial Institutions Examination Council BSA/AML Manual, as needed.
- Meet with the Financial Crime Enforcement Network (FinCEN) at least annually to discuss the operation of the Memorandum of Understanding and to identify any issues or adjustments that may be required. The OIG urged NCUA to “document any revised agreements and update the agency’s policies to communicate the FinCEN reporting requirements and information needed from the regions and the Office of National Examinations and Supervision.”
- Develop and implement an efficient process that ensures the completeness, accuracy, timeliness, and validity of information obtained from the agency’s MERIT, such as establishing reports, to meet the agency’s BSA reporting objectives. The OIG said this includes communicating information in accordance with the Memorandum of Understanding and other agreement(s) with FinCEN.
- Revise the content of the NCUA’s Enforcement Manual to include current policies, procedures, and responsibilities for the NCUA’s formal enforcement actions and ensure its content is consistent with other agency policies. The OIG recommended NCUA regularly review this guidance for continued relevance and effectiveness in achieving the agency’s objectives.
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