1 Purpose
This policy establishes the Credit Union's program to comply with the Bank Secrecy Act and its implementing regulations, and to detect and report money laundering, terrorist financing and other financial crime.
2 Scope
Applies to every product, service, delivery channel and employee of the Credit Union, and to third parties acting on its behalf.
3 Program
3.1 BSA Officer
The Board designates the AVP Compliance as BSA Officer, responsible for day-to-day compliance with this policy and for reporting to the Board at least annually.
3.2 Customer due diligence
The Credit Union identifies and verifies the beneficial owners of each legal entity member at account opening, as required by 31 CFR 1010.230, and maintains a member risk profile that is updated on a risk basis.
3.3 Customer identification program
Before opening an account the Credit Union collects and verifies the name, date of birth, address and identification number of each member, under the CIP rule at 31 CFR 1020.220.
4 Reporting
4.1 Suspicious activity
Suspicious activity is escalated to the BSA Officer and, where required under 31 CFR 1020.320, reported on a SAR within 30 calendar days of initial detection.
4.2 Currency transactions
Currency transactions over $10,000, and multiple transactions that aggregate over $10,000 in one business day, are reported on a CTR under 31 CFR 1010.311.
5 Training and testing
Every employee completes BSA training annually. The program is tested independently at least every 12 to 18 months and the results are reported to the Board.
6 Review
This policy is reviewed annually, and whenever a regulatory change affects it, by the BSA Officer and the Board.