Risk & Compliance Review – Part I: Are you moving forward in the most efficient manner?
Thursday, January 10, 2019
Posted by: Trichina Pierce, CCUL Risk Management Resources
For most organizations, the end of the year is synonymous with open enrollment time for employee benefits. As I reviewed my benefit options in December 2018, I found myself wondering, “Was I getting the same benefit as last year or was I making the same elections I did in previous years?” Going through this comparative/review process also left me asking, “What other areas of my life need an annual review?”
Now, apply that thought process to your credit union’s governance, regulatory and compliance practices/policies and you’re on your way to effective risk management. But knowing how to review is as equally important to the review itself. So, before we press on in 2019, let’s make sure your credit union is up-to-date for 2018 by running through this checklist.
Risk Regulatory Checklist:
1. Review BSA rules and regulations. On December 17, 2018, FinCEN assessed $14.5 Million penalty against UBS Financial Services for Anti-Money Laundering failures. Within a week, the FDIC announced the release of an updated technical assistance video on the Bank Secrecy Act (BSA), anti-money laundering (AML) requirements, and the Treasury Department's Office of Foreign Assets Control (OFAC) sanctions programs. The updated video provides an overview of current BSA/AML and OFAC requirements. Access the video here.
Among other things, the updated video reflects the new beneficial ownership and customer due diligence requirements and related examination procedures as described in FIL 26-2018 dated May 11, 2018, titled: Bank Secrecy Act: Customer Due Diligence and Beneficial Ownership Examination Procedures.
Additional BSA resources to keep your credit union up-to-date include NCUA BSA Resources, Ballard Spahr LLP’s Money Laundering Watch Podcast, and FinCEN’s Money Services Businesses (MSB) search tool.
2. Stay up to date on the latest consumer issues and regulatory changes. The following resources cover some of the top issues from 2018, including:
3. Complaints as a Supervisory and Risk Management Tool
Still not sure what an effective complaints management system looks like? Then check out this webinar. No matter how small or large your credit union is an effective compliance management system should be a fundamental backbone to any supervisory committee and risk team. Access the Federal Reserve’s archived webinar here.
In Part II of this article series, we’ll take a look at the subjects that should be on your risk regulatory checklist for 2019. For questions or comments on credit union governance, risk or compliance issues, contact the Carolinas Credit Union League’s Risk Management Resources Department at firstname.lastname@example.org or contact any member of our team.