Dear Boards of Directors and Chief Executive Officers:
The Anti-Money Laundering Act of 2020 (AML Act)1 requires the Secretary of the Treasury, in consultation with the Attorney General, federal functional regulators,2 relevant state financial regulators, and relevant national security agencies, to establish and make public priorities for anti-money laundering and countering the financing of terrorism policy (AML/CFT Priorities).3 On June 30, 2021, the Secretary of the Treasury issued the AML/CFT Priorities (opens new window).
The NCUA is issuing this Letter to Credit Unions with the attached interagency statement to provide the following:
- NCUA plans to revise its BSA regulations, as necessary, to address how the AML/CFT Priorities will be incorporated into credit unions’ BSA requirements.
- Credit unions are not required to incorporate the AML/CFT Priorities into their risk-based BSA compliance programs until the effective date of a final revised regulation.4
- Examiners will not examine for incorporation of AML/CFT Priorities into BSA compliance programs until a final regulation implementing the AML/CFT Priorities becomes effective.
- Credit unions may wish to start considering how they will incorporate the AML/CFT Priorities into their risk-based BSA compliance programs.
NCUA continues to work closely with FinCEN and our federal and state counterparts to ensure a high level of transparency and flexibility as we work to implement the changes required through regulation and supervision in the AML Act.
Please contact your Regional Office or state supervisory authority if you have questions about this letter or the attached statement.
Todd M. Harper
2 31 U.S.C. § 5318(h)(4)(A) (as amended by AML Act § 6101(b)(2)(C)) uses the term “Federal functional regulator” as defined in section 509 of the Gramm-Leach-Bliley Act (15 U.S.C. § 6809).
3 31 U.S.C. § 5318(h)(4)(A) (as amended by AML Act § 6101(b)(2)(C)).
4 The AML Act of 2020 requires that FinCEN in consultation with the Federal functional regulators and relevant State financial regulators promulgate regulations, as appropriate, within 180 days of establishing the AML/CFT Priorities.