NEWPORT, R.I. — When it comes to Bank Secrecy Act compliance the risk based regulatory structure is the challenge says NAFCU Regulatory Compliance Director Anthony Demangone.
"You run into the Monday morning quarterback issue where you can second guess everything that happened in Sunday night's game," said Demangone. "It's hard to know what you need to do or invest in until credit unions do individual review or risk assessment of products, members, services and locations–almost a BSA strategic plan if you will before you can determine if you need to buy software or hire new employees."
He adds that the issue is that credit unions are judged after the fact either through an audit of the program or NCUA exam and they then have to defend their actions.
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