NCUA issues examination guidance for BSA Customer Due Diligence and Beneficial Ownership Compliance

Aug. 27, 2018 -- Today, the NCUA issued examination procedures to field staff regarding customer due diligence and beneficial ownership provisions that are part of the Bank Secrecy Act/Anti Money Laundering Rules (BSA/AML).

The Agency further issued a supervisory letter to federally insured credit unions with the examination expectations provided to the NCUA examiners regarding the review of a credit union’s compliance with these areas. This includes new examination procedures that will be incorporated into the Federal Financial Institutions Examination Council (FFIEC) Bank Secrecy Act/Anti-Money Laundering Examination Manual. NCUA has also consolidated BSA resources for credit unions on the NCUA website.

NCUA asserted that the rules are intended to “strengthen and codify customer due diligence requirements for covered financial institutions.” The institutions are now required to identify and verify the identity of individuals (the beneficial owners) who own or control certain business accounts, subject to exclusions and exemptions.

NCUA recognizes that some credit unions may need additional time to implement changes and to comply with the new requirements, thus the Agency instructed examiners to accept a credit union’s reasonable and good faith efforts to comply with the new rule throughout 2018. However, NCUA also noted that the Agency’s acceptance of good faith efforts for supervision purposes does not shield a credit union from FinCEN penalties that could arise from failing to comply with all BSA/AML requirements.


Examination Guidance for Bank Secrecy Act Customer Due Diligence and Beneficial Ownership Compliance (LTCU 18-CU-02)

NCUA Bank Secrecy Act pages