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Building a Credit Union
Compliance Program

Article preview:

Heightened Bank Secrecy Act scrutiny over large financial institutions has disrupted money-laundering logistics, redirecting criminal deposits into credit unions and smaller banks. A confidential FinCEN report that leaked in 2015 reveals the scope of the problem, identifying 50 credit unions with elevated anti-money laundering risks.

In order to survive in a regulatory regime that is increasingly holding smaller banks to the same standards as large institutions, credit unions must adopt new controls to confront evolving anti-money laundering threats. Central to the creation of a best-in-class credit union compliance program are the following: the designation of a chief risk officer; upgrading regtech assets to identify money services businesses (MSB) exposure and other risks; ensuring policies are comprehensive; and taking corrective action ahead of regulatory notice. The following article will examine these best practices for implementation by credit unions.

Key takeaways:

Smaller banks and credit unions are increasingly becoming a target of criminal AML activity. This article outlines the top steps credit unions need to take to ensure they have the adequate compliance program in place, including:

  • Designate a Chief Risk/Compliance Officer
  • Upgrade Regtech with a Focus on MSB Vulnerabilities
  • Enact Comprehensive Policies
  • Take Corrective Action Ahead of Regulatory Retaliation

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