(July 16, 2021) Rule changes to incorporate just-issued national priorities for combatting money laundering and financing of terrorism – as outlined in an NCUA Letter to Credit Unions (LTCU) late last month — are summarized by NASCUS and posted this week; like all summaries, it is available to members only.
Late last month, NCUA issued LTCU 21-CU-05, which detail priorities for anti-money laundering (AML) efforts and countering the financing of terrorism (CFT) set by the Treasury’s Financial Crimes Enforcement Network (FinCEN). The priorities describe “the most significant AML/CFT threats currently facing the United States,” according to FinCEN. The priorities include corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and human smuggling, and proliferation financing.
NCUA (as stated in its letter to credit unions) indicated that while it is not required to do so, the agency plans to propose changes to its own BSA rules addressing the priorities. Credit unions (as well as banks and nonbanks, the target of a separate FinCEN statement) are not required to make any changes in their risk-based BSA compliance programs, and examiners will not review institutions for incorporation of the AML/CFT priorities into those programs, until the effective date of a final rule, NCUA and FinCEN said.
Also in its letter, NCUA said credit unions “may wish to start considering how they will incorporate the AML/CFT Priorities into their risk- based BSA compliance programs.”