As I was sitting in yet another airport terminal waiting for a flight home, the TV monitor showed a CNN breaking news story on Eliot Spitzer troubles. As evidence that I picked the correct career path, I was less interested in the details of what he did than in how it was initially detected. When the CNN anchor mentioned the phrase “structured transaction,” the story took on a whole new meaning for me. The same Bank Secrecy Act (BSA) requirement that led to the most shocking scandal of the week is the same requirement that is all too familiar to credit unions.

For the past couple of years, credit union regulatory compliance has been dominated by BSA concerns. Whether it is multi-million dollar penalties assessed against banks or cease and desist orders and documents of resolutions against credit unions, BSA violation headlines demand our attention. Credit unions have invested heavily on bolstering their BSA compliance programs. In this environment, it is easy to think that regulatory compliance is entirely BSA compliance.

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