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ALEXANDRIA, Va.-NCUA wrote a guidance letter to corporate credit unions (No. 2005-01) Feb. 23 on Bank Secrecy Act requirements for `batched’ items. Previous guidance said it was reasonable to expect corporates to periodically check its monetary instruments record for characteristics of structuring in non-batched items, which could be easily detected. These characteristics can include common names, addresses and account numbers among the transferors; common names, destinations and account numbers among transferees; the frequency and schedule of the transactions; and whether the amounts of the transactions fall just below a BSA recordkeeping or reporting minimum. It did not address the `unbatching’ of previously batched transactions, for which corporates may need to run sort patterns or other processes for telltale signs of structuring. Once a corporate converts the batched data to a form that could make structuring apparent, it triggers “a due diligence responsibility to determine whether there is “reason to know or suspect” a violation of BSA anti-money laundering rules.” “Regardless whether the corporate itself or a third-party vendor performs such services, the due diligence liability remains with the corporate credit union,” the guidance read. NCUA Director of the Office of Corporate Credit Unions Kent Buckham noted that the letter was intended for `guidance’ only. “Each corporate credit union must make a comprehensive review of every transaction processing activity engaged in, assess its due diligence requirements, and immediately effect compliance with the BSA and its implementing regulations,” he wrote.

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