1. Bank Secrecy Act

2. Many Laws Make Up “BSA” Bank Secrecy Act Money Laundering Control Act Currency and Foreign Transactions Reporting USA PATRIOT Act

3. BSA Basics Reporting Recordkeeping

4. Currency Transaction Reports Currency transactions greater than $10,000 Aggregate same-day transactions File in 15 days

5. Exemptions Automatic Phase I Phase II

6. Exemptions Application Annual Review Ineligible Entities

7. Geographic Targeting Notice from FinCEN Expanded CTR reporting or other transaction reporting

8. Suspicious Activity Reports Funds from illegal activities Evading BSA reporting requirements No business or apparent lawful purpose

9. SAR Limits Insider abuse in any amount $5000 more with a suspect $25,000 without a suspect

10. Suspicious Activity Reports File within 30 days Maintain supporting documentation Supporting documentation can be requested without legal process Keep confidential Report to the Board

11. Recordkeeping Filed Reports Certain Credit Extensions Geographic Targeting Orders

12. Monetary Instruments Cash sales between $3,000 and $10,000 Cashier’s checks, teller’s checks, money orders, traveler’s checks (not gift cards) Specific records required

13. Wires Over $3000 Transactions subject to Reg E are exempt Different requirements if the CU is the originating bank or beneficiary bank

14. Information Sharing 314(a): Required searches through FinCEN 314(b): Voluntary sharing between financial institutions

15. Customer Identification Programs 1. Obtain identifying information 2. Verify identity 3. Maintain records 4. Check government lists 5. Provide information collection notice

16. Required Information Name Date of Birth Address Identification Number

17. Verifying Identity Form a reasonable belief of member’s identity Review various identification methods ID methods must be listed in the CU’s CIP

18. Government Lists Crickets Chirping......

19. Record Retention All identifying information Description or copy of documents used Notes of unusual circumstances Keep for five years

20. CIP Notice Provide before account opening Various delivery methods are available