Joint Statement on Risk-Focused BSA/AML Supervision Released


The federal banking agencies, along with Financial Crimes Enforcement Network (FinCEN) released a joint statement on risk-based Bank Secrecy Act/Anti-Money Laundering (BSA/AML) supervision as a way to improve transparency. The statement does not establish new requirements, but notes that having a risk-based compliance program enables credit unions to allocate compliance resources commensurate with risks. 

The statement outlines common practices for assessing a credit union’s risk profile. The conclusion of the statement is that risk-focused BSA/AML examinations consider the credit union’s unique risk profile. Examiners will use risk assessments and independent testing when planning and conducting examinations, and will assess the adequacy of the credit union’s compliance program during each exam cycle. The extent of the exam activities necessary to evaluate the credit union’s BSA/AML compliance program generally depend on a credit union’s risk profile and the quality of its risk management processes to identify, measure, monitor, and control risks. 

Question of the Week 

CORRECTION. Last week’s question concerned, in part, the use of a journal by a notary. In the answer to the question, we erroneously indicated that there is no requirement in Washington for a notary to keep a journal. That was true in the past, but as of July 1 of 2018, a Washington notary is required to maintain a journal of notarial acts. 

Here is what the Washington State Department of Licensing recommends: 

Q. Am I required to keep a journal?

A. As of July 1, 2018, you’re required to maintain a journal of notarial acts.

The journal must be: 

  • A permanent, bound book with numbered pages. An electronic journal can be kept in addition to the physical journal, but can’t replace it. 
  • Kept in a locked and secured area under your exclusive control. 
  • Kept for 10 years after the last notarization recorded in the journal. 

Journal entries must be made at the time of the notarization and must include: 

  • The date and time of the notarization. 
  • A description of the document or act being notarized. 
  • Full name, address, and signature of each person for whom the notarization was performed. 
  • Brief description of the identification method. 

If you resign your commission, or if your commission is suspended or revoked, you must let us know where the journal is located. 

We thank Gayleen Ronk at Washington Employees Credit Union for catching the error and for contacting us. 

Related Links 

WA Notary FAQs 

Legal Briefs 

National Credit Union Administration (NCUA) 

NCUA released a joint statement as part of an effort to improve transparency into the risk-based approach to BSA/AML supervision. 

NCUA’s final rule on appraisals has been published in the Federal Register. Effective date of rule, Oct. 22, 2019. 

NCUA’s final rule on fidelity bonds has been published in the Federal Register. Effective date of rule, Oct. 22, 2019. 

Consumer Financial Protection Bureau (CFPB) 

CFPB released an ANPR seeking information related to the expiration of the temporary qualified mortgage provision applicable to certain mortgage loans eligible for purchase by the GSEs. 

Federal Trade Commission (FTC) 

The FTC released information on the Equifax Data Breach Settlement, which credit unions can leverage to help members who may wish to file a claim. 

Social Security Administration (SSA) 

Reminder: SSA Initial Enrollment period for Electronic Consent Based Social Security Number Verification period ends July 31, 2019. There will be additional enrollment periods that will open up in the future if a credit union missed the initial enrollment period. 

United States Department of Labor (DOL) 

DOL released a rule that will allow small businesses to offer retirement savings plans to their works through Association Retirement Plans (ARPs), which allow small businesses to band together to offer retirement plans to their employees. 

Internal Revenue Service (IRS) 

IRS has begun sending letters to virtual currency owners advising them to pay back taxes. 

Office of Foreign Assets Control (OFAC) 

OFAC has updated the SDN list as of July 25, 2019. The last update prior to this was July 22, 2019. 

Questions? Contact the Compliance Hotline: 1.800.546.4465;

Posted in Compliance News.