In all three financial institutions, international wires and transfers are reviewed for BSA compliance with corporates maintaining a parallel structure "with the same basic component parts" as the CU.

Hence, Members United has a designated BSA officer and must complete independent testing and staff education, she said. Training needs to be multi-faceted, as not every employee touches the transactions at the same level, she continued. Members United trains the team responsible for filing SARs, breaking it down according to member and nonmember contact employees, each with uniquely focused programs.

Regarding the customer identification program under BSA, Virkler noted that the majority of entities doing business with the corporate are exempt from the CIP designation. Members United does, however, obtain information to confirm the existence of CUSO members, leagues and trade associations served by the corporate, she said.

"More important than the identification of the credit union members of the corporate is the 'risk profile' required for compliance," she said. Members United must understand the makeup of CU membership, their cash usage trends, and the typical money transfer transactions that flow through to the corporate.

"The 'risk profile' helps the corporate find examples of unusual trends," she said.

Virkler identified the many ways in which corporates review transactions by their members and that includes all money transfers, whether an international wire, a domestic wire or a Western Union transaction.

"These are not only reviewed based on one credit union and the associated consumers, but across the membership for a single consumer," she said. This view is looked upon as "structuring." It is possible for the corporate to see multiple transactions from multiple credit unions by the same consumer.

If the corporate provides coin and currency to the member CUs, these transactions must be reviewed, she said, noting also that an exemption from filing a CTR for this service must be filed by both the corporate and the CU.

Just like CUs, corporates must review transactions for suspicious activity and file SARs when warranted. But if a SAR is filed regarding a transaction that flowed through a CU, the corporate will NOT be able to inform the CU.

Credit unions using their corporate must also be looking for SARs, but file their own separate reports, she concluded. –[email protected] OFAC Rules Could Tighten Warns Attorney

LAS VEGAS — Heightened regulatory scrutiny on foreign transactions could be on the way for credit unions as the possible result of close new ties between credit union regulators and an agency of the U.S. Treasury, Washington attorney Judith A. Lee, a specialist in financial trade law, told a Credit Union Times/Executive Enterprise Institute conference here.

Lee, a partner at Gibson, Dunn & Crutcher, said a new agreement reached Dec. 4, between the New York State Banking Department and the Office of Foreign Assets Control could spell tighter examination of CU foreign dealings with individuals and businesses.

The pact between OFAC and the New York agency signals a new "bosom buddies" linkup, which means regulators could be paying far more attention to foreign transactions than in the past, said Lee. In her remarks, she stressed that OFAC has undergone a reshuffling in recent months with a new leadership team far more "outgoing" in approach and much more eager than in the past to share data with other agencies. Calling the New York agreement "a harbinger of things to come," Lee told attendees at the Credit Union Times conference at Caesar's Palace she understands OFAC intends to expand the pact to other states with plans underway to meet with the National Association of State Credit Union Supervisors. –[email protected]