BSA & OFAC

Compliance Audits

The Five Pillars

In 1970, the Bank Secrecy Act (BSA) established the requirements for Credit Unions and other financial institutions to implement Anti-Money Laundering (AML) and financial crimes safeguards.

In order to be in compliance with the BSA, a Credit Union must develop and maintain procedures to fulfill these requirements—known as the "five pillars" of BSA/AML compliance.

Develop a program of internal safeguards to support ongoing compliance.
Appoint a BSA Compliance Officer to maintain the financial institution's BSA audit program and ensure that it is followed.
Perform independent testing of BSA policies and procedures.
Train employees in procedures to ensure compliance of internal controls.
Create and follow internal policies to identify beneficial owners of customer legal entities.

The Office of Foreign Asset Control

The Office of Foreign Asset Control (OFAC) enforces economic sanctions which target foreign countries, terrorist organizations, and internal narcotics traffickers.

While the OFAC requirements are not part of the BSA, they share similar goals for national security. Therefore, it is common to review OFAC compliance and internal procedures concurrent with BSA/AML examinations.

Our Services

We offer the annual independent audit required by the National Credit Union Administration (NCUA), which includes:

Evaluating internal controls
Testing samples for compliance
Deciding if personnel are adequately trained
Examining Current Transaction Reports (CTRs) and Suspicious Activity Reports (SARs)
Reviewing the Customer Information Policy and Customer Notice
Testing record-keeping procedures