Bank Secrecy Act (BSA) & USA Patriot Act


  • Ensure your credit union is compliant with all regulatory requirments related to BSA/AML/OFAC and that associated risks are properly mitigated


CU Rx will review the following areas:

  • BSA Risk Assessment
  • Products & Services
  • Member & Entities
  • Geographic Locations
  • Internal COntrols
  • Policies & Procedures
  • Transaction Testing
  • Currency transaction reports (CTRs)
  • Suspicious activity reports (SARs)
  • Effective of Training
  • Customer identification program (CIP)
  • OFAC

A vital and mandatory component to a Bank Secrecy Act (BSA) compliance program is the provision for independent testing or auditing to ensure compliance. Whether performed by internal or external staff, an effective audit plays an important role in independently evaluating risk management, controls and effectiveness of compliance with BSA/AML/OFAC. Policy statements alone are not sufficient; practices must coincide with the credit union's written policies, procedures and processes.

Credit Unions must establish and maintain a written compliance program for fulfilling the requirements of the Bank Secrecy Act (BSA) that includes at least:

  1. A system of internal controls
  2. Designation of an individual to coordinate/monitor BSA compliance
  3. Independent testing
  4. Training of appropriate personnel.

In addition, an effective BSA compliance program should include written policies and procedures designed to detect and prevent money laundering activities. CU Rx will assess the effectiveness of the credit union's BSA/AML compliance program and the credit union's compliance with BSA regulatory requirements, including a review of risk management practices.