Historically, credit unions (CUs) had a well-defined and lower risk customer base. Recent regulatory enforcement actions against banks, however, have resulted in de-risking programs that may drive riskier customers such as Money Service Bureaus, payment processors and cash checkers, to open accounts at CUs. Regulators are focused on the impact that this customer shift could have on anti-money laundering (AML) risks for CUs.
Given the changing environment, CUs should consider enhancing core areas of their AML program. Based on extensive experience working with financial institutions on AML compliance programs and investigations, Navigant has published Heightened Regulatory Focus on AML Risk in the Credit Union Industry. This article provides practical compliance program recommendations to help CUs get a head start to proactively manage AML risk.