plan and report its findings to the Board of Directors. This audit will be performed at least every 12 to 18 months. MONITORING. The Credit Union will enact procedures to monitor and identify unusual activity. As part of the monitoring process, the Credit Union Member Due Diligence. will enact a member due diligence program in order to: (a) predict the types of transactions in which a member is likely to engage; and (b) determine when transactions are potentially suspicious. High Risk Members. For high risk members, the Credit Union will obtain the following information at account opening and throughout the relationship: Purpose of the account. Source of wealth and funds. Individuals with ownership or control over the account, such as beneficial owners, signatories, or guarantors. beneficial and type of business. Member’s (or owner’s) occupation Financial statements. Residence (if a business, where it is incorporated). Proximity of residence, place of employment or business to the Credit Union. Whether international transactions are expected to be routine. Explanations for changes in account activity. Description of business operations, anticipated volume of currency and sales. References. Correspondent and Private Banking Accounts. [[2110-3]] The PATRIOT Act requires enhanced due diligence policies, procedures, and controls reasonably designed to detect and report money laundering or potential terrorist activities conducted through correspondent accounts for foreign banks or through private banking accounts (For the purposes of the PATRIOT Act, a account is one in which the Credit Union requires a “private banking” minimum balance of at least $1,000,000 and is managed by a specific Credit Union employee). Money Service Businesses (MSBs). MSBs include any person doing business, regardless of whether on a regular basis, in one or more of the following: money orders, travelers checks, money transmissions, check cashing and currency dealing or exchange. Must conduct more than $1,000 in business with one person in one or more transactions on any one day (however, NO activity threshold applies to money transmitters). When opening an account for an entity, the Credit Union will at a minimum, conduct the following due diligence for MSBs: Apply the Credit CIP/MIP; Union’s Confirm whether it has registered with FinCEN (as it is required to do every two (2) years. If not, the account will not be opened);
plan and report its findings to the Board of Directors. This audit will be performed at least every 12 to 18 months. MONITORING. The Credit Union will enact procedures to monitor and identify unusual activity. Member Due Diligence. As part of the monitoring process, the Credit Union will enact a member due diligence program in order to: (a) predict the types of transactions in which a member is likely to engage; and (b) determine when transactions are potentially suspicious. High Risk Members. For high risk members, the Credit Union will obtain the following information at account opening and throughout the relationship: Purpose of the account. Source of wealth and funds. Individuals with ownership or control over the account, such as beneficial owners, signatories, or guarantors. Member’s (or beneficial owner’s) occupation and type of business. Financial statements. Residence (if a business, where it is incorporated). Proximity of residence, place of employment or business to the Credit Union. Whether international transactions are expected to be routine. Explanations for changes in account activity. Description of business operations, anticipated volume of currency and sales. References. Correspondent and Private Banking Accounts. [[2110-3]] The PATRIOT Act requires enhanced due diligence policies, procedures, and controls reasonably designed to detect and report money laundering or potential terrorist activities conducted through correspondent accounts for foreign banks or through private banking accounts (For the purposes of the PATRIOT Act, a “private banking” account is one in which the Credit Union requires a minimum balance of at least $1,000,000 and is managed by a specific Credit Union employee). Money Service Businesses (MSBs). MSBs include any person doing business, regardless of whether on a regular basis, in one or more of the following: money orders, travelers checks, money transmissions, check cashing and currency dealing or exchange. Must conduct more than $1,000 in business with one person in one or more transactions on any one day (however, NO activity threshold applies to money transmitters). When opening an account for an entity, the Credit Union will at a minimum, conduct the following due diligence for MSBs: Apply the Credit Union’s CIP/MIP; Confirm whether it has registered with FinCEN (as it is required to do every two (2) years. If not, the account will not be opened);
2110BankSecrecyActAMLProgram.docx