ALEXANDRIA, Va. — Garden Savings Federal Credit Union, without admitting or denying fault, agreed to a Cease & Desist Order from NCUA for Bank Secrecy Act noncompliance.

The administrative order, released today, states that the credit union has agreed to contract an outside audit firm within 60 days of the order, signed by all the credit union’s board as recently as June 25, to correct deficiencies; complete a risk assessment’ keep a list of high and moderate risk members; file all missing Currency Transaction Reports and Suspicious Activity Reports as well as the back CTRs for improperly exempted businesses within 30 days; establish written high-risk member policies and procedures within 90 days; hire a “competent, full-time” BSA compliance officer and approve a job description for the BSA officer within 90 days; ensure necessary training of the BSA officer; obtain and research all FinCEN 314(a) information sharing within 14 days of the request; establish a training program within 90 days; implement and maintain adequate internal controls; and evaluate the current Customer Identification Program, among many other requirements.

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