The World Council of Credit Unions urged the Basel Committee on Banking Supervision to strive for greater clarity in its recent "Sound Management of Risk Related to Money Laundering and Financing of Terrorism" consultative document. The Basel Committee's AML rules are one of the international standards that influence U.S. credit unions' Bank Secrecy Act compliance requirements.

Specific suggestions included clarification of the term "financial inclusion" as one relating to all members, not just those considered "financially or socially disadvantaged," according to a Sept. 27 letter by Michael Edwards, WOCCU vice president and chief counsel, to Wayne Byers, the Basel Committee's secretary general.

Edwards' letter also asked the committee to clarify that it is not mandatory for institutions to use expensive vendor-created compliance software. He said the cost of such systems sometimes outweighs the potential benefits based on the institution's complexity and risk requirements compared to anti-money laundering risks and efforts to combat the financing of terrorism.

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