FinCEN on Promoting a Culture of Compliance; NAFCU Member Call-In

Written by Shari R. Pogach, Regulatory Paralegal

I recently attended the 2014 Mid-Atlantic Anti-Money Laundering Conference held here in Washington, DC, and heard Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery speak on the fundamental importance of a culture of compliance to strengthen any Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program.  One of the things Shasky Calvery noted was that it is not always easy to convey the need for a strong culture of BSA/AML compliance to a financial institution’s board of directors, leadership or senior management.  To assist with this, FinCEN has issued an advisory, FIN-2014-A007.  FinCEN’s advisory explains how a financial institution and its leadership can improve and strengthen organizational compliance with BSA obligations by ensuring that:

1. Leadership is actively supporting, understanding and engaged with compliance efforts;
2. Any efforts to manage and mitigate BSA/AML deficiencies and risks are not compromised by an institution’s interest in revenue;
3. Any relevant information throughout the organization is shared with compliance staff to advance BSA/AML efforts;
4. Leadership provides adequate human and technological resources;
5. The compliance program is effective and tested by an independent and competent party; and
6. The organization’s leadership and staff understand the purpose of its BSA/AML efforts and how the reports are used. 

FinCEN’s advisory is intended to be another tool to be used to influence an organization’s leadership, “to make it easier for them to live and breathe BSA/AML the same way that you do…….Because once you have a strong culture in place, including the support of your institution’s leadership, you have a firm foundation on which to build an effective program.” 

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A Credit Union Industry Update – You shouldn't miss NAFCU’s member call-in on Tuesday, September 23, 2014, from 4:00-5:00 pm ET, as NAFCU President and CEO Dan Berger and other NAFCU senior staff will brief member credit unions on the latest legislative, regulatory, compliance and economic issues affecting credit unions.  Participation is free for all NAFCU members, but you must register to attend.