Thursday, March 20, 2008

BSA compliance: Where is the Sect 326 list?

WASHINGTON (2/8/08)— Credit union personnel keeping track of compliance requirements associated with the USA Patriot Act probably wonder what ever became of an elusive list named by the act., according to the Credit Union National Association's (CUNA's) Compliance Challenge.

Section 326 of the USA Patriot Act requires institutions to check "a list of known or suspected terrorists or terrorist organizations issued by any Federal government agency and designated as such by Treasury in consultation with the Federal functional regulators."

But did the federal government ever issue a "Section 326 List"?

"To date, no such list has been issued," says Valerie Moss CUNA's director of compliance information

"For the time being, credit unions need to check any lists issued by the Office of Foreign Assets Control (OFAC) and respond to the Financial Crime Enforcement Network's (FinCEN) 314(a) requests for information."

CUNA will let credit unions know if the elusive 326 List ever appears, she adds.

Use the resource link below for more on this and other compliance topics.

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