Last month, at the CUNA/NASCUS BSA school, NCUA’s Judy Graham described the 5 most common BSA mistakes examiners find during examinations:
1. Inadequate Risk Assessment: NCUA recommends that credit unions take the time to review all products and services to determine where BSA risks may exist, such as business accounts and wire transfer activity. Make sure you have adequate internal controls to meet these risks.
2. SAR Monitoring: Make sure your SAR procedures and monitoring systems have been updated to keep up with your credit union’s growth and sophistication. Ensure that the technology running your products and services is communicating with your SAR monitoring system.
3. Training: Ensure your board of directors and supervisory committee are receiving appropriate training that is commensurate with the risk profile of your credit union. Also, training should be individualized to each department of the credit union and occur every 12-18 months.
4. Independent Testing: Make sure your independent testing covers ALL AREAS OF YOUR OPERATION and occurs every 12 -18 months.
5. Section 314(a): Ensure your credit union is checking FinCEN’s Section 314(a) lists as they are coming in – DO NOT FALL BEHIND.