ARLINGTON, Va.—What did NCUA mean when it said it recently said it would accept "reasonable and good faith efforts to comply" with the Financial Crimes Enforcement Network's (FinCEN) customer due diligence (CDD) and beneficial ownership provisions?
NAFCU is offering an answer after updated supervisory guidance and Bank Secrecy Act (BSA) questionnaire was released last month by the agency, with Regulatory Paralegal Shari Pogach outlining in a blog post a list of questions NCUA examiners will consider when examining for compliance with the new CDD and beneficial ownership requirements.
Pogach said NCUA field staff through the rest of 2018, "will be looking for a credit union's awareness of, and will review its efforts to comply with, the new requirements."
"Then in 2019, NCUA field staff will begin more in-depth reviews of a credit union’s BSA/AML policies, procedures and processes in order to assess overall compliance with regulatory requirements for CDD and for identifying and verifying beneficial owner(s) of legal entity members," Pogach added.
In addition, FinCEN has made permanent exceptive relief for certain financial products that are deemed to be lower risk for money laundering such as share certificate rollovers and loan renewals. NAFCU said it will provide a detailed analysis of the announcement later this week.