Thank you for sharing!

Your article was successfully shared with the contacts you provided.

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.

Complete your profile to continue reading and get FREE access to CUTimes.com, part of your ALM digital membership.

Your access to unlimited CUTimes.com content isn’t changing.
Once you are an ALM digital member, you’ll receive:

  • Critical CUTimes.com information including comprehensive product and service provider listings via the Marketplace Directory, CU Careers, resources from industry leaders, webcasts, and breaking news, analysis and more with our informative Newsletters.
  • Exclusive discounts on ALM and CU Times events.
  • Access to other award-winning ALM websites including Law.com and GlobeSt.com.

Already have an account?


Credit Union Times

Join Credit Union Times

Don’t miss crucial strategic and tactical information necessary to run your institution and better serve your members. Join Credit Union Times now!

  • Free unlimited access to Credit Union Times' trusted and independent team of experts for extensive industry news, conference coverage, people features, statistical analysis, and regulation and technology updates.
  • Exclusive discounts on ALM and Credit Union Times events.
  • Access to other award-winning ALM websites including TreasuryandRisk.com and Law.com.

Already have an account? Sign In Now
Join Credit Union Times
Live Chat

Copyright © 2022 ALM Media Properties, LLC. All Rights Reserved.