Letter to Credit Unions: Risk-Based Approach to Assessing Member Risk

NCUA logo

In a July 6 letter to credit unions, the National Credit Union Administration (NCUA), the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the U.S. Department of Treasury’s Financial Crimes Enforcement Network released a joint statement clarifying its position that banks and credit unions must take a risk-based approach to assessing individual customer (member) risk. The joint statement reinforces the NCUA’s position that no single customer type automatically presents a high risk of money laundering, terrorist financing, or other illicit financial activity risk.

The regulations established in the Bank Secrecy Act (BSA) establish a risk-based approach to assessing customer relationships and conducting customer due diligence. The NCUA expects credit unions to assess the risks posed by each customer individually. Further, the NCUA advises against refusing service or discontinuing service to an entire class of customers based on perceived risk. Credit unions that comply with BSA and anti-money laundering (AML) requirements and have an effective customer due diligence program in place are well-positioned to manage customer relationships and risks appropriately, based on each individual customer relationship.

View the Letter to Credit Unions (22-CU-08) here.

Pin It