Bank Secrecy Act for Operations Staff

Presented by Jan Vogel, Center for Professional Development WilliamsTown Communications, Contributing Writer

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Introduction Welcome to CUNA’s Bank Secrecy Act for Operations Staff Training on Demand course! Compliance with the Bank Secrecy Act, otherwise known as the BSA, is a critical task for each and every credit union in the United States, so all credit union employees must be familiar with BSA requirements. To that end, this course provides an overview of the Bank Secrecy Act, including specific actions that you, as a member of your credit union’s operations staff, must take to be BSA compliant. Of course, you also need to be sure that you know What Is the the BSA policy and procedures at your credit union. Bank Secrecy Act? This is key to being in compliance with the require- Not surprisingly, the first step to BSA compliance ments of the Bank Secrecy Act. is understanding just what the Bank Secrecy Act in- Let’s get started! volves and why it was enacted in the first place. In its current form, the BSA is more than just a single act of Objectives Congress; rather, it is a combination of multiple laws The Bank Secrecy Act applies to all credit unions, that have been passed during the last four decades. and it requires that employees in these institutions These laws were enacted to assist law enforcement carry out certain tasks. But what exactly does the officials in the investigation of activities and crimes BSA entail, and how does it affect operations staff such as money laundering, tax evasion, and financing in particular? By the end of this Training on Demand of terrorist groups. Collectively, these acts and their course, you’ll know the answers to these questions. related regulations require that financial institutions In fact, upon completing the course, you will be able obtain specific information, maintain certain records, to: and report certain financial transactions to the federal government. • Explain the Bank Secrecy Act (BSA); Today, BSA enforcement is the responsibility of • Know when to file Currency Transaction Reports an agency called the Financial Crimes Enforcement (CTRs) and Suspicious Activity Reports (SARs); Network, or FinCEN. FinCEN is a bureau of the United • Explain the requirements for wire transfer pay- States Department of the Treasury. ment orders and monetary instrument purchases; • Understand how to apply Customer/Member Identification Programs; and • Explain the purpose of 314(a) and 314(b) information sharing.

2 Laws That Comprise Bank Secrecy Act of 1970 the Bank Secrecy Act The Bank Secrecy Act of 1970 is the foundation upon which the current version of the BSA was built. As described earlier, the Bank Secrecy Act is not a So, what did this act entail? In short, the primary single law, but rather a combination of multiple laws purpose of this law was to prevent financial institu- that have been enacted at the federal level. Some of tions — including credit unions — from being used as the most important of these laws include the following: intermediaries in currency transactions that might be • The Bank Secrecy Act of 1970; linked to money laundering, tax evasion, and other • The Anti-Drug Abuse Act of 1986; criminal activities. To accomplish this goal, the Bank • The Money Laundering Control Act of 1986; and Secrecy Act of 1970 standardized recordkeeping and reporting requirements for all financial institutions • The USA PATRIOT Act of 2001. in the United States. Many of these requirements will Although each of these laws deals with a different be discussed in greater detail later in this book. topic, each also has the same basic purpose: to create a paper trail for currency transactions. Let’s take a look Anti-Drug Abuse Act of 1986 at each of these laws in greater detail. A second major law that helped shape today’s BSA was the Anti-Drug Abuse Act of 1986. This law was passed during a period of rising concern about the many negative effects of illicit drugs on American society. Therefore, the act sought to strengthen the U.S. government’s “War on Drugs” efforts by: • Helping law enforcement thwart illicit drug crops; • Stopping international drug trafficking; • Improving the enforcement of existing anti-drug laws; and • Establishing more effective drug abuse and prevention programs. Most notably for the purposes of this course, the Anti-Drug Abuse Act of 1986 also set the stage for the first piece of legislation to outlaw money laundering: the Money Laundering Control Act of 1986.

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ent areas in its efforts to root out and prevent terrorism, one particular area of concern relates to the financing of terrorist activities. Accordingly, the PATRIOT Act authorized the U.S. Department of the Treasury to issue regulations requiring all financial institutions in the United States to: • Have minimum standards to verify the identity of new members when opening accounts; • Have anti-money laundering programs in place; • Search their records for information if requested by Money Laundering FinCEN; and Control Act of 1986 • Compare the names of new members with a govern- As previously described, the Money Laundering ment list of known or suspected terrorists. Control Act of 1986 strengthened the BSA by making Currently, this particular list has not yet been re- money laundering a federal crime. In particular, the leased. For the time being, all credit unions should Money Laundering Control Act resulted in regula- screen their new members against the list of Specially tions that: Designated Nationals and Blocked Persons (SDN list) • Criminalized the act of money laundering; released by the U.S. Office of Foreign Assets Control, or OFAC. • Prohibited the act of structuring transactions to evade currency transaction report (CTR) filings; and How the BSA Affects Credit Unions The National Credit Union Administration (NCUA) is • Introduced both civil and criminal penalties for responsible for ensuring that all credit unions comply violations of the BSA. with the provisions of the Bank Secrecy Act. In particu- More information about CTR filings is provided later lar, during their periodic review of a credit union’s op- in this book. erations, NCUA examiners ensure that the credit union has all five elements of an effective BSA program in USA PATRIOT Act of 2001 place. These elements are as follows: Finally, yet another piece of legislation that played 1. A system of internal controls —including a significant role in shaping the BSA was the USA policies and proce-dures —to ensure ongoing PATRIOT Act of 2001. This law’s full name is the BSA compliance; “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct 2. A BSA officer — in other words, a staff member Terrorism Act,” and it was passed in the wake of the with appropriate resources and authority who terrorist attacks of September 11, 2001. is responsible for coordinating and monitoring Although the PATRIOT Act focuses on many differ- BSA compliance;

4 3. A program that trains employees with regard to of $10,000.01 or more. This amount includes multiple BSA compliance; and same-day cash transactions completed at any credit 4. An independent testing program to monitor union branch by, or on behalf of, the same individual internal compliance. or entity. For the purposes of a CTR, deposits made at night, over a weekend, or on a holiday are treated as if 5. Risk-based procedures for ongoing they are received on the next business day. member/customer due dilligence. The following transactions are similar to those you During an NCUA examination, all employees can be are likely to encounter at your credit union. These asked to prove that they know and understand BSA re- should help you determine when to file a CTR. quirements. In other words, compliance with the Bank Secrecy Act isn’t just the duty of the BSA officer — it’s Scenario 1: Betty comes into your credit union’s Main everyone’s responsibility. Street branch with $12,000 in currency and wants to deposit that money into her savings account. Do you need to file a CTR? Currency Transaction This is an easy one! Because the transaction involves Reports more than $10,000 in currency, you must file a CTR for this transaction. What must you and your credit union do to comply with the BSA? You must always follow the BSA regula- Scenario 2: John withdraws $11,500 in currency in tions related to Currency Transaction Reports, or CTRs. the morning. Later that day, he deposits $6,000 in cur- Under current federal regulations, all financial institu- rency back into his account, saying he didn’t need all of tions — including credit unions — are required to file the money. Should you file a CTR? a CTR any time they process a deposit, withdrawal, or Yes, you should. Even though the total dollar amount exchange of cash in excess of $10,000. In other words, going out of John’s account is only $5,500, you still a CTR is required for each and every cash transaction need to file a CTR for the original $11,500 cash withdrawal. Scenario 3: Fred deposits $6,000 in cash into his share draft account in the morning. Later that day, his broth- er wants to deposit $5,000 cash into Fred’s share draft account. Do you file a CTR? Yes, a CTR must be filed, because all cash transactions made in the same day to the same account either by the account holder or for the account holder must be aggregated. One easy way to remember when to file a CTR is by re- calling the following phrase: “More than $10,000 today, a CTR is on the way.” http://www.fincen.gov/forms/bsa_forms/ 5 Filing CTRs • The credit union has been the victim of insider Completed CTRs must be filed no later than the fif- abuse involving funds in any amount. teenth day following the date of the cash transaction. When you recognize that a CTR needs to be com- Filings SARs pleted, you may inform the member that you are filing Whenever an SAR is required, it must be filed with a report. However, it’s usually best to keep the details FinCEN within 30 days of the suspicious activity. of the filing to yourself! Also, whenever you complete a However, if a suspect has not yet been identified, filing CTR, be sure to verify the member’s basic information, can be delayed for up to 30 additional days. SAR filings including name, address, and taxpayer ID number. are confidential—this means that applicants may not Remember, it’s essential that you follow your credit be informed that a filing has occurred. In fact, if an ap- union’s specific policies regarding who completes and plicant even asks whether an SAR has been filed, that files CTRs! inquiry must be reported as well. Within your credit union, everyone is responsible for detecting and reporting suspicious activ- Suspicious ity. Federal “Safe Harbor” legislation means that Activity Reports you cannot be prosecuted for filing an SAR in good Another important tool involved in the prevention faith — so don’t be afraid to do so! Still, be absolute- and detection of money laundering is the Suspicious ly sure that you know and follow your credit union’s Activity Report, or SAR. Under federal regulations, you procedures regarding who actually completes and are required to file an SAR for any suspicious transaction files your organization’s SARs. activity — no matter whether it involves cash, check, wire transfer, or Automated Clearinghouse (ACH). Reasons to File an SAR But under what circumstances should you complete As you can imagine, there are many reasons why a an SAR? Per federal guidelines, this form must be filed credit union might decide to file an SAR. Some exam- in any of the following situations: ples include: • The credit union has been the victim of a • Check fraud; criminal violation involving an aggregated • Computer intrusion; amount of $25,000 or more, and a suspect has not been identified. • Credit or debit card fraud; • The credit union has been the victim of a crimi- • Embezzlement; nal violation involving an aggregated amount of • Mortgage loan fraud; $5,000 or more, and a suspect has been identified. • Identity theft; and • The credit union has conducted a transaction of • Terrorist financing. $5,000 or more and knows, suspects, or has Two of the most common reasons for filing are trans- reason to suspect that money laundering or action structuring and wire transfer fraud. Because BSA violations have occurred.

6 these reasons are so common, we’ll take a closer look $4,000 in currency on Thursday. This makes a total at both of them in the following sections. aggregated cash deposit of $11,000. In this scenario, the credit union would not file a CTR because the deposits were not made on the same business day. Transaction Structuring However, the credit union would want to monitor the As previously mentioned, transaction structuring is account to see whether Betty’s ongoing activity in- one of the most frequent reasons why credit unions dicates a pattern of structuring to avoid CTR filings. file SARs. But what exactly is “structuring”? In short, Then, after reviewing Betty’s account activity, the structuring occurs whenever an individual tries to credit union’s BSA officer would need to determine if evade CTR filing by splitting a reportable transaction an SAR should be filed. into multiple, smaller dollar-amount transactions, each of which falls under the $10,000.01 threshold. Sometimes structuring is easy to spot. For ex- Wire Transfers ample, say that Joe comes into your credit union In addition to structuring, wire transfer fraud is with $15,000 in currency but decides to only deposit another major reason why credit unions file SARs. $6,000 into his share account when he learns that In fact, to help detect and prevent fraud in this a CTR will be filed. This is clearly structuring, so the area, credit unions are required to record and retain credit union must file an SAR on the transaction. the following information for all wire transfers in In other cases, structuring may not be so easy to amounts of $3,000 or more: detect. For instance, say that Betty deposits $3,000 • The name and address of the payment’s in currency into her share draft account on Monday, originator; $4,000 in currency on Wednesday, and another • The amount and execution date of the payment order and any other instructions received; • The identity of the beneficiary’s financial institution; and • The beneficiary’s name, address, and account number (if provided). This information must be obtained at the time the payment order is accepted, and it must “travel” with the order to the receiving financial institution. Finally, it’s important to note that transfers for less than $3,000, transactions governed by the Electronic Fund Transfer Act and Regulation E (such as ATM and point-of-sale transactions), and ACH transactions are not covered by these rules.

7 Wire Transfers and SARs tion in any format that is both accurate and easily ac- Now you know what information you need to record cessible. Specifically, for each cash purchase between and retain for wire transfers—but do you know how to $3,000 and $10,000, there must be a record of: spot a transfer that would require you to file an SAR? In • The purchaser’s name; short, when reviewing wire transfers for signs of suspi- • The date of the purchase; cious activity, be sure to stay alert for any and all transfers that fall outside the scope of a member’s normal • The type of instrument that was purchased; account activity or line of business. • The serial number of the instrument; and For example, say that during the month of March, your • The dollar amount of the transaction. credit union’s wire transfer department receives 29 wire transfers totaling $900,000 for deposit into Anderson Although it is not required, it is also highly recom- Rental Service’s share draft account. Then, one day af- mended that you verify the identity of the individual ter each of these transfers is completed, the associated purchasing the instrument. funds are wired directly to Ed Johnson’s personal account But what about purchases of monetary instruments at another financial institution. Here, based on your re- greater than $10,000? In these situations you do not search on the company’s account, you determine that the need to obtain the information listed above; however, if received and subsequent transfers are outside the normal the instrument is purchased with cash, then a CTR must scope of Anderson Rental Service’s business. Therefore, be filed. In contrast, if the purchase does not involve these transactions should raise a red flag for your credit cash, then the CTR rule does not apply. Note though, union’s BSA officer, and an SAR should be filed. that some credit unions may have a policy that requires members to deposit cash prior to purchasing a monetary instrument in that amount. When this is the case, Monetary Instruments the credit union is required to obtain and retain the five pieces of information discussed earlier. As yet another crime detection practice, current BSA regulations also require that credit unions document cash sales of certain monetary instruments. In particular, if a credit union sells a cashier’s check, teller’s The USA PATRIOT Act check, money order, traveler’s check, or other mon- and BSA Compliance etary instrument to a person in an amount from $3,000 As mentioned near the beginning of this book, the to $10,000 and this purchase is made with cash, the USA PATRIOT Act of 2001 established several provi- credit union must collect and maintain certain informa- sions that affect the way financial institutions do busi- tion in its records. ness. The provisions of greatest importance to credit When the recordkeeping requirement for monetary union operations staff are those related to Member instrument transactions was first established in 1988, Identification Programs and to information sharing, this information had to be kept in a centralized log. The both between financial institutions and between finan- log requirement was eliminated in 1994. Today, credit cial institutions and the federal government. unions are required to keep a record of the informa-

8 Customer/Member 2. Entities that are not legal persons are subject to the credit union’s MIP. Examples include clubs, Identification Programs estates, and unincorporated businesses. (Note, Let’s start our discussion of the PATRIOT Act by fo- however, that a business may be considered a cusing on Section 326 of that statute. This section “legal person” in some instances.) When deal- is important because it requires that all financial ing with these sort of entities, your credit union institutions establish what is known as a Customer must verify the identity of the organization’s Identification Program (CIP)—or, in the case of a credit representative, as well as the identities of any union, a Member Identification Program (MIP). No mat- other individuals who will be conducting trans- ter what name the program goes by, it must require the actions on the organization’s account. implementation of reasonable procedures to verify the identity of any person who seeks to open an account. 3. For the purpose of MIPs, legal entities are con- As part of its CIP or MIP, the financial institution must sidered members too. This means that prior to record and maintain all of the information it used to opening a legal entity account, you must verify verify a person’s identity. the identity of the legal entity, all those who will conduct transactions on the account, and Who Should Be Subject to Your CIP/MIP? the beneficial owners of the legal entity. A legal How do you determine whether someone should or entity is any corporation, LLC, or other company should not be subject to your credit union’s Member that is created by filing with the Secretary of Identification Program? Thankfully, there are guide- State or similar office. A beneficial owner is any lines for making this determination: person that has 25% or more ownership inter- est in the entity, and one person with significant 1. Every individual who seeks to open a new ac- control of the day to day operations on the en- count should be subject to your credit union’s MIP. tity. Generally, existing members are not subject to MIP requirements. However, if the credit union is not 4. All individuals who lack legal capacity— comfortable that it “knows” the member based including minors—are subject to your credit on previously obtained information, the credit union’s MIP. For instance, when working with union should consider obtaining additional or minors, a credit union has a number of verifica- more recent information. For example, credit union tion options. One option is to verify the identity members who opened accounts before the current of the minor’s parent, legal guardian, or next standards were put in place may not have provided of kin. Alternatively, if identification is avail- the more extensive identification information re- able (such as a student ID), the credit union may quired under the USA PATRIOT Act. In addition, it’s positively identify the minor or allow someone important to remember that each person named on else (usually a parent or guardian) to vouch for a joint account is considered a member and their the minor’s identity. identity must be verified. Of course, not all people and organizations that apply for an account at your credit union will be subject

9 to its MIP. In particular, the stringent identification business as” a different name, you must still get rules associated with MIPs do not apply to the follow- the legal name of the potential account holder. ing account applicants: 2. Second, you must obtain the applicant’s date of • Persons with an existing account with the credit birth, including month, day, and year. union—provided that the credit union has a rea- 3. Third, you must obtain the applicant’s address. sonable belief that it knows the member’s true identity; 4. And fourth, you must obtain an identification number for the applicant. • Signatories (or authorized signers) on accounts; Because the exact type of address and ID information • Other financial institutions; or you require varies depending on the type of applicant, • Government agencies. let’s take a closer look at these requirements.

Information Required Identification Numbers You’ve determined an account applicant is sub- As mentioned earlier, you must obtain the identifica- ject to your credit union’s Member Identification tion number of any applicant for a new account. You Program. Now what? At a minimum, you are required have several options available to you, depending on to obtain the following four pieces of information the applicant’s citizenship and residency status: from the individual: • If the person is a U.S. citizen or is authorized to 1. First, you must obtain the person’s legal name. work in the United States, you should generally ask Note that even if the applicant will be “doing for his or her Social Security Number. • If, however, the applicant does not have a Social Security Number, you should obtain his or her Individual Taxpayer Identification Number (ITIN), Alien Identification Number, and/or passport number, along with the country of issuance. When using a document issued by a foreign government, make sure it evidences nationality or residence and bears a photograph or other safeguard. If the applicant is an entity rather than an individual, you should obtain the applicant’s Employer Identification Number (EIN).

Address Requirements As previously mentioned, the third piece of critical information you must obtain when verifying identity is

10 the applicant’s address. The exact requirements vary depending on whether the applicant is an individual or an entity: • For individuals, the credit union must obtain a residential or business street address. A post office box is not acceptable, although it can be used for mail- ing purposes. • For individuals without a residential or business street address, you may accept an Army Post Office (APO) box number, a Fleet Post Office (FPO) box number, or the residential or business street address of the person’s next of kin or other contact individual. • For corporations, partnerships, or trusts, your credit union must record the address of the applicant’s principal place of business, local office, or other physical location. Federal regulations are specific about what counts Remember, these four pieces of information—name, as a “document” in the context of an MIP, and they date of birth, address, and ID number—represent a provide different lists of acceptable documents for minimum requirement. In all cases, you should get as individuals and for corporations, partnerships, and much information as you need to establish a reasonable trusts. In particular: belief that you know the true identity of the account • When applying for new accounts, individuals applicant. must present unexpired government-issued identification evidencing nationality or resi- Verifying Information: dence and bear- The Documentary Method You now know what four critical pieces of informa- ing a photo. Examples of acceptable documents tion must be obtained as part of any CIP or MIP. But include a person’s passport or driver’s license. how can you verify that this information is authentic? • In contrast, corporations, partnerships, and According to federal regulations, your credit union’s trusts must present one or more documents prov- MIP must contain procedures describing when vari- ing their existence as an entity. Acceptable docu- ous pieces of information will be verified through ments include certified articles of incorporation, government-issued documents, as well as which types government-issued business licenses, partner- of documents it will accept. This manner of using ship agreements, and trust instruments. government-issued documents is known as the documentary method of verification.

11 Verifying Information: The Nondocumentary Method But what if an account applicant cannot provide any of the documents we discussed? Can your credit union still verify the applicant’s identity? According to the USA PATRIOT Act, the answer to this question is yes—you just have to rely on an alternate method of verification known as the nondocumentary method. This method of verification is appropriate in situations where: • An individual is unable to present unexpired, government-issued identification; • The credit union is not familiar with the documents the applicant presents; lent, so it is often wise to use a combination of both the • The account is not being opened in person; or documentary method and the nondocumentary method to verify identity, especially in cases where you are un- • The type of account being opened increases the comfortable with the documents being provided. risk that the credit union will not be able to identify the applicant using documents. (This would include accounts opened by mail and via online What If an Applicant’s banking.) Identity Can’t Be Verified? As described in the previous sections, documentary As you might expect, the nondocumentary method and nondocumentary methods can be used to verify involves consideration of information other than the identity of an account applicant. But what if nei- government-issued documents. With this method, ther method proves an applicant’s identity? Your cred- your credit union can independently verify an ap- it union’s MIP needs to explain what to do in these plicant’s identity by comparing the information the situations. In fact, your MIP should address all of the applicant provides against items such as utility bills, following: statements from other financial institutions, rental agreements, or public databases. However, the most • When the credit union should not open an account; common methods involve running a credit report on • The terms under which members may use an ac- the applicant and/or running the applicant’s infor- count while their identities are still being verified; mation through a check verification service. • When the credit union should close an account Usually, more than one nondocumentary piece of after attempts to verify a member’s identity have identification is required before an account can be failed; and opened, depending on your credit union’s policy. Also, remember that even seemingly “official” docu- • When the information received during the verifi- ments can be obtained illegally and may be fraudu- cation process should trigger the filing of an SAR.

12 Information to Record be accurate and accessible within a “reasonable pe- What type of information should be included in your riod” of time. credit union’s records? In short, your records must in- No matter what method your credit union uses, clude a description—and not a copy—of any document though, it is critical that you familiarize yourself with you relied on to verify an applicant’s identity. This de- the organization’s record retention procedures and scription should detail the following: follow them at all times! • The type of document used; Notice Requirements • The identification number listed on the document; Before you can record any information, however, • The document’s place of issuance; your credit union must provide notice to potential • The document’s date of issuance; members that certain information will be collected during the verification process. This requirement, • The document’s expiration date; and which is a result of the PATRIOT Act and its related • A description of any substantive discrepancies that regulations, states that notice must be given in a were discovered when verifying the information manner “reasonably designed” to ensure that the ap- received from the applicant. plicant is able to view or receive the notice prior to Remember, this information must be kept for five opening an account. For example, the credit union years after a record of it is made! Your credit union can post a notice regarding ID requirements in the can store this information on paper, or use electronic lobby, on its website, on a handout, or on the new ac- means to satisfy its MIP retention requirements. If it count application form, depending on how the credit opts for the second method, all electronic records must union allows individuals to apply for new accounts. Members of the credit union’s staff can also orally provide notice to account applicants.

Member/Customer Due Diligence Programs Financial institutions are also expected to have a due diligence program in place that goes beyond the standard MIP requirements. In fact, a due diligence program is considered the cornerstone of a strong BSA compliance program. A good due diligence program must be designed to enable a credit union to obtain enough information at account opening to develop an understanding of the normal and expected activity for a particular member and/or account. This will allow the credit union to predict which types of transactions are “nor-

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Sections 314(a) and 314(b) of the PATRIOT Act are especially important. Section 314(a) deals with information sharing between financial institutions and the federal government, whereas Section 314(b) focuses on information sharing between financial institutions. Let’s take a closer look at each section.

Section 314(a) Under Section 314(a) of the USA PATRIOT Act, FinCEN is authorized to request information from financial institutions throughout the United States on behalf of law enforcement agencies that are investigating money laundering or terrorist activity. These requests are made once every two weeks, and all financial institutions—including credit unions—are required to have a designated contact person who receives FinCEN’s requests. Once a credit union receives an information request, it must scan its records for possible matches. If the mal” for that member or that account. credit union identifies a match, it must then report that As you might expect, periodic monitoring of mem- fact to FinCEN. ber accounts is a requirement for any due diligence Credit unions have two weeks from the transmission program. This allows the credit union to stay current date of the request to respond to FinCEN. Also, credit with any substantial changes to the information unions are prohibited from disclosing the fact that originally gathered regarding the member and the FinCEN has requested or obtained information under account. In addition, regular monitoring makes it the rule, except to the extent necessary to comply with easier for the credit union to detect transactions that the request. seem unusual or suspicious. Be sure to read and understand all of the procedures outlined in your credit union’s member due Section 314(b) Section 314(b) of the PATRIOT Act also deals with diligence program. information sharing. This section allows credit unions and other financial institutions to share information Information Sharing with each other after filing notification with FinCEN. It’s Under the USA PATRIOT Act critical to remember that the notice to FinCEN must be filed before any information sharing takes place! In ad- As mentioned earlier, one other topic of particular dition, the financial institutions that are sharing data concern to credit union operations staff is informa- must have procedures in place to protect the security tion sharing. When it comes to information sharing,

14 and confidentiality of the shared information. • Understand how to apply Customer/Member So, when is this sort of data sharing permitted? In Identification Programs; and short, financial institutions may share information for • Explain the purpose of 314(a) and 314(b) purposes of detecting, identifying, or reporting activi- information sharing. ties that involve possible money laundering or terrorism. Also, the sending institution must verify that the receiving institution is on an approved government list Above all, remember this: Knowing and following before transmitting any information to that institution. your credit union’s BSA policy and procedures is criti- You can view the Info Sharing Notice by visiting the cal to being in compliance. Take time to review those FinCEN website: https://www.fincen.gov/314b/314b_ documents! notification.php Final Exam Summary To register for the final exam go to Congratulations on completing CUNA’s Bank Secrecy training.cuna.org and click on CPDOnline Act for Operations Staff Training on Demand course! You under LOG IN at the left hand side of the screen. should now be able to: • Explain the Bank Secrecy Act (BSA); • Know when to file Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs); • Explain the requirements for wire transfer payment orders and monetary instrument purchases;