Written by Shari R. Pogach, Regulatory Paralegal
Compliance with Bank Secrecy Act (BSA) and the Office of Foreign Assets Control (OFAC) requirements continues to be an issue for some financial institutions. Towards the end of 2015, the Board of Governors of the Federal Reserve System posted enforcement actions against three banks: The Bank of Nova Scotia of Toronto, Canada; East West Bank of Pasadena, California; and Habib Bank Limited of Karachi, Pakistan. Each bank had varying degrees of problems with its BSA and anti-money laundering (AML) compliance programs as well as OFAC compliance. All are now subject to monitoring, reporting and transaction lookback review as a result of the deficiencies. It is sometimes helpful to review what someone else has or is doing wrong to ensure your own compliance program is up to snuff.
Cuba and Iran Sanctions
We all know there have been significant changes announced to U.S. policy concerning Cuba and Iran. As a result, there have also been some changes to the OFAC requirements for both countries. I thought it might be help to post the following FAQs from OFAC on the changes:
BSA Blast: The January 2016 quarterly issue of the BSA Blast is now available (a NAFCU login required). This issue takes a look at the enforcement actions against Deutsche Bank AG for U.S. sanctions violations and reviews recent speeches made by the Financial Crimes Enforcement Network Director Jennifer Shasky Calvery. The issue also includes a new BSA quiz for staff training on OFAC reporting and record keeping requirements.
NAFCU Webcast: Register for this live webcast, Bank Bribery Issues from a Board Member’s Perspective, on Wednesday, January 27, from 2-3:30pm EST. The role of a credit union board member is more significant than ever. And, a director has the ultimate decision making authority and responsibility for controlling the direct operations of the credit union, which also means understanding the internal and external entities that affect decision making. Join us for an in-depth look at rules, regulations and best practices regarding bank bribery issues that every director needs to know. During the webcast, we will review examples and case studies of Bank Secrecy Act (BSA) violations, explore ethics rules and required policies for internal dealings, and more
Programming Note: Winter Storm Jonas is coming so NAFCU is closing at 12 noon today to ensure folks get home safely. But never fear, for those not impacted by Jonas, the Regulatory Compliance team will still be available to answer your questions remotely.