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Email #1: WHAT TO EXPECT

A welcome message from Donya — click on the link above.

Who Is Providing the Emails? 

The emails are a dues service through your credit union's affiliation with Montana's Credit Unions, an association supporting credit unions across the state. My name is Donya Parrish, and as the VP Risk Management at MCU, I cover our compliance hotline and host a monthly call with compliance officers. Those calls often discuss BSA challenges, exam focus, and more. I've also had my BSA Compliance Specialist (BSACS) designation from America's Credit Unions for almost twenty years and have the opportunity to do BSA training with many credit unions and their boards each year. Those conversations give me a good perspective of the climate of BSA across Montana and it is my goal to share that with you this week.

 

What Will Be Covered? 

Each day this week (December 9-13), you'll receive two daily emails that cover a particular aspect of the Bank Secrecy Act. One will arrive mid-morning and another in the mid-afternoon. The email topics will range from understanding reporting and risk assessments to resources and information sharing. This series is designed to build upon itself, so you'll get the most benefit if you participate in all ten emails. 


What Should I Expect? 

You can expect short articles summarizing various components of the BSA with links to additional details and information. There will be questions to get you thinking about your own credit union's role with Bank Secrecy Act compliance, as well as information on recent events and helpful resources. You can read the emails independently or discuss them as a department or group within your credit union.


What If I Miss a Day? 

Each series email will be in your inbox, so even if you're out of the office or are too busy to concentrate on compliance training at the time, it will be there. They will also be available in the archive on our Compliance Training Tools page after each series email is sent for easy access all year! That can be an option to bring new employees up to speed on the regulation prior to your next scheduled credit union-wide BSA training.

 

Will There Be a Final Test?

Yes! On Friday, December 13, you'll receive a third email in the afternoon that includes an optional self-test to see how knowledgeable you are on BSA requirements. Whether your credit union or supervisor wants to see the results of your test should be discussed internally. Keep in mind that this series is not intended as a substitute to familiarity with your own credit union's policy, procedures, and expectations on BSA compliance.


How Can I Prove I Completed It?

The series and self-test are made available to Montana credit unions as a tool, but it's up to each credit union to decide how to track or manage the outcomes. Visit with your BSA compliance officer or supervisor if you have any questions regarding their expectations. We will also provide a certificate that can be filled in upon completion of the test and/or series for bragging rights.

WHO ARE THE REGULATORY AGENCIES?

Financial Crimes Enforcement Network (FinCEN) has primary oversight of the BSA regulation. As the law enforcement arm of the U.S. Treasury Department, they collect reports, manage the program, and facilitate sharing between law enforcement and financial institutions. They also manage a few programs within the BSA regulations that we'll discuss more this week.


FinCEN Website

NCUA Seal in Blue

The NCUA (National Credit Union Administration) is the primary regulator for federal credit unions, and also insures most state and federal credit union accounts. Their BSA interest is with the safety and soundness of those credit unions and protection of the share insurance fund. NCUA also reports quarterly to FinCEN on any BSA exams they perform and findings within them. 


NCUA Website

Our Montana Division of Banking & Financial Institutions, under the Montana Department of Administration and the direction of Commissioner Melanie Hall, regulates state chartered credit unions. They include BSA as a topic within the exams for those state credit unions and work closely with federal regulatory agencies on compliance and oversight.


Division Website

SOME BSA FACTS

THE BANK SECRECY ACT was originally published on October 26, 1970, and signed into law by President Richard Nixon.


IT IS ALSO KNOWN as the Currency and Foreign Transactions Reporting Act.


THERE WERE UPDATES over the years with the addition of the Money Laundering Control Act of 1986, the Anti-Drug Abuse Act of 1988, the Money Laundering Suppression Act of 1994, the Money Laundering and Financial Crimes Strategy Act of 1998, the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act), and the recent Corporate Transparency Act (CTA). There is also a current proposal to update the AML/CFT (Anti-Money Laundering and Countering the Financing of Terrorism) provisions. We'll likely know more about that in 2025.


YOU CAN FIND more historical facts about AML laws here.

Next Topic

MONEY LAUNDERING

Access the 2024 BSA email series archive on our Compliance Training Tools page after each email sends. You'll also find other BSA and compliance training webinars and materials.

Donya Parrish, VP Risk Management | donya@mcun.coop | 406-459-3497