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    Credit unions everywhere are faced with the challenges of passing their Bank Secrecy Act examination. This exam also incorporates OFAC and the USA Patriot Act (Customer Identification Program – CIP). This article will assist your credit union in addressing those challenges by laying out the important components associated with this task.

    Policies and procedures:

    Policies need to address the credit union’s commitment to insuring overall compliance by Management, the Board of Directors, Supervisory Committee, and the credit union’s entire staff.

    BSA also includes the Currency Transaction Report (CTR), the Suspicious Activity Report (SAR), the Report of Foreign Bank and Financial Accounts (FBAR) and the Report of International Transportation of

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    t Act (Customer Identification Program – CIP). This article will assist your credit union in addressing those challenges by laying out the important components associated with this task.

    Policies and procedures:

    Policies need to address the credit union’s commitment to insuring overall compliance by Management, the Board of Directors, Supervisory Committee, and the credit union’s entire staff.

    BSA also includes the Currency Transaction Report (CTR), the Suspicious Activity Report (SAR), the Report of Foreign Bank and Financial Accounts (FBAR) and the Report of International Transportation o

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    nents associated with this task.

    Policies and procedures:

    Policies need to address the credit union’s commitment to insuring overall compliance by Management, the Board of Directors, Supervisory Committee, and the credit union’s entire staff.

    BSA also includes the Currency Transaction Report (CTR), the Suspicious Activity Report (SAR), the Report of Foreign Bank and Financial Accounts (FBAR) and the Report of International Transportation o

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    e by Management, the Board of Directors, Supervisory Committee, and the credit union’s entire staff.

    BSA also includes the Currency Transaction Report (CTR), the Suspicious Activity Report (SAR), the Report of Foreign Bank and Financial Accounts (FBAR) and the Report of International Transportation o

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    rt (CTR), the Suspicious Activity Report (SAR), the Report of Foreign Bank and Financial Accounts (FBAR) and the Report of International Transportation of Currency or Monetary Instruments (CMIR).

    The CIP must address: receipt of certain identifying data on anyone who opens an account; verification of the identity of any customer who opens an account; maintenance of records; determination of whether the person appears on any government list; and, notice to the person that the credit union will be requesting information to verify identity.

    The USA Patriot Act further requires the credit union to check their database against the Section 314(a) requests.

    Credit union's BSA policy also needs to include: a system of internal controls, the designat

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