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Training risk calculations continue to be BSA challenges
WASHINGTON (8/23/11)—During a Bank Secrecy Act (BSA) webinar hosted by the Credit Union National Association (CUNA) Friday, Judy Graham, of the National Credit Union Administration’s (NCUA) office of examination and insurance, said examiners identify risk assessments and staff training as two top areas of compliance problems. According to Graham, examiners continue to find that some credit unions do not have a written assessment, or have inadequate assessments, of their risks to exposure to BSA and money laundering activities. She noted that risk assessments should be reviewed for appropriateness when there is a merger or expansion of products, services or membership. On a related issue, Graham also noted that some suspicious activity monitoring programs being implemented are being found to be insufficient to manage the risks involved in the credit union's business. Regarding staff training for BSA requirements, Graham said examiners are finding that training is often dated or hasn't been documented. Although the timing of training will vary based on the risks of the credit union's business, NCUA expects training to be done at least annually. Riskier, more complex credit unions may find it appropriate to train more frequently. Also, training should incorporate regulatory changes and relevant guidance. Thomas Lawler, of the Financial Crimes Enforcement Network FinCEN),and Michael Dondarski, of the Office of Foreign Asset Control, also participated in the CUNA webinar. Lawler provided insight into FinCEN's role in implementing the BSA statute and outlined several recent regulations and guidance documents FinCEN has issued over the last year, such as a Suspicious Activity Report (SAR) Confidentiality Rule and the Money Services Business rule. OFAC’s Dondarski provided an overview of OFAC's economic sanction programs and an Executive Order that was issued on Aug. 18, which extensively broadened the scope of OFAC's Syria program. Credit unions were encouraged to contact the OFAC compliance hotline at 800-540-6322 and the OFAC licensing division at 202-622-2480 with any questions. And, credit unions were encouraged to have members contact OFAC directly with any questions regarding blocked property or rejected transactions. An archived version of the CUNA webinar is available via the resource link below.

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