MADISON, Wis.–The World Council of Credit Unions has sent a comment letter to the Financial Action Task Force (FATF) about anti-money laundering/countering the financing of terrorism (AML/CFT).
World Council’s comment letter follows on oral comments made at a FATF consultative meeting in March at the United Nations Office on Drugs and Crime in Vienna.
The WOCCU comment letter focuses on three areas:
· Correspondent Banking: WOCCU urged the FATF to make sure that national governments like the U.S. issue local version of the FATF’s Correspondent Banking Services guidance it issued in October 2016. FinCEN and OFAC did issue a fact sheet on correspondent banking in August 2016, but have not yet issued more detailed guidance on correspondent banking services that is based on the FATF guidance, WOCCU noted. It pointed out that once adopted locally, the increased clarity on correspondent banking AML/CFT responsibilities should make it easier for credit unions to establish and maintain correspondent banking accounts.
· Customer Due Diligence for the Unbanked: WOCCU wrote that CU examiners typically review all member accounts that do not have a Social Security Number, even though U.S. credit unions are allowed to use non-documentary methods of identification in order to do customer due diligence for unbanked persons who do not have standard identification (like a passport of driver’s license). WOCCU commented that the examination risks associated with accounts that do not have social security numbers may have deterred some credit unions from serving unbanked persons who lack standard identification.
· Information Sharing: WOCU commented that the USA Patriot Act does allow credit unions to share AML/CFT information with law enforcement, other financial institutions, and with financial institution associations, but asked for the Patriot Act’s rules permitting AML/CFT information sharing to become global so a U.S. credit union can share information that can help resolve a foreign correspondent bank’s “red flag.”
The full letter can be found here: http://www.woccu.org/documents/FATF_Info_Sharing_Correspondent_Banking_Fin_Inclusion_CDD_Apr_2017