Audit of the NCUA's Bank Secrecy Act Enforcement Program

Submitting OIG:

National Credit Union Administration OIG

Report Description:

The National Credit Union Administration (NCUA) Office of Inspector General (OIG) conducted this self-initiated audit to assess the NCUA’s Bank Secrecy Act (BSA) program. The objectives of our audit included determining whether the NCUA: (1) adequately reviewed compliance with the Bank Secrecy Act during credit union safety and soundness examinations, (2)issued timely formal or informal enforcement actions to address Bank Secrecy Act-related violations, (3) tailored enforcement actions to address deficiencies identified during the supervisory process, (4) followed up on reported Bank Secrecy Act violations to ensure credit unions take appropriate corrective action before closure of the violation, and (5) appropriately referred significant Bank Secrecy Act violations and deficiencies to the Financial Crimes Enforcement Network, a bureau within the United States Department of the Treasury.

Short / Alternative Report Title:

Audit of the NCUA's Bank Secrecy Act Enforcement Program

Date Issued:

Thursday, May 30, 2024

Agency Reviewed / Investigated:

National Credit Union Administration

Submitting OIG-Specific Report Number:

OIG-24-06

Location(s):

Agency-Wide

Type of Report:

Audit

Questioned Costs:

Funds for Better Use:

Number of Recommendations:

Report updated under NDAA 5274:

View Document:

Attachment	Size
OIG-24-06-Audit-NCUAs-BSA-Enforcement-Program508compliant.pdf	1.69 MB

Additional Details Link:

https://ncua.gov/files/audit-reports/oig-audit-bsa-enforcement-program.pdf

Recommendation Number	Recommendation Status	Significant Recommendation	Additional Details
1. OIG-24-06	Open	No	Audit of the NCUA's Bank Secrecy Act Enforcement Program
Update the Bank Secrecy Act scope tasks and questions within the Modern Examination and Risk Identification Tool to ensure examiners complete and document all necessary steps during Bank Secrecy Act examinations and direct examiners to use additional external guidance such as the National Supervision Policy Manual, Examiner’s Guide, and Federal Financial Institutions Examination Council BSA/AML Manual, as needed.
2. OIG-24-06	Open	No	Audit of the NCUA's Bank Secrecy Act Enforcement Program
Meet with the Financial Crime Enforcement Network (FinCEN), no less often than annually, to discuss the operation of the Memorandum of Understanding and to identify any issues or adjustments that may be required. Document any revised agreements and update the agency’s policies to communicate the FinCEN reporting requirements and information needed from the regions and the Office of National Examinations and Supervision.
3. OIG-24-06	Open	No	Audit of the NCUA's Bank Secrecy Act Enforcement Program
Develop and implement an efficient process that ensures the completeness, accuracy, timeliness, and validity of information obtained from the agency’s Modern Examination and Risk Identification Tool, such as establishing reports, to meet the agency’s Bank Secrecy Act reporting objectives, including communicating information in accordance with the Memorandum of Understanding and other agreement(s) with the Financial Crimes Enforcement Network.
4. OIG-24-06	Open	No	Audit of the NCUA's Bank Secrecy Act Enforcement Program
Revise the content of the NCUA’s Enforcement Manual to include current policies, procedures, and responsibilities for the NCUA’s formal enforcement actions and ensure its content is consistent with other agency policies. Regularly review this guidance for continued relevance and effectiveness in achieving the agency’s objectives.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

1. OIG-24-06

Open

Audit of the NCUA's Bank Secrecy Act Enforcement Program

Update the Bank Secrecy Act scope tasks and questions within the Modern Examination and Risk Identification Tool to ensure examiners complete and document all necessary steps during Bank Secrecy Act examinations and direct examiners to use additional external guidance such as the National Supervision Policy Manual, Examiner’s Guide, and Federal Financial Institutions Examination Council BSA/AML Manual, as needed.

2. OIG-24-06

Open

Audit of the NCUA's Bank Secrecy Act Enforcement Program

Meet with the Financial Crime Enforcement Network (FinCEN), no less often than annually, to discuss the operation of the Memorandum of Understanding and to identify any issues or adjustments that may be required. Document any revised agreements and update the agency’s policies to communicate the FinCEN reporting requirements and information needed from the regions and the Office of National Examinations and Supervision.