Recordkeeping and Reporting Requirements under the Bank Secrecy Act

Congress has expressed a great deal of concern recently about the effect of drug trafficking on our society. As a result of that concern, Congress passed, and the President signed, the Anti-Drug Abuse Act of 1986. This law affects your recordkeeping and reporting obligations under the Bank Secrecy Act and the Department of Treasury's regulations.

As required by Congress, NCUA recently adopted a regulation requiring federally-insured credit unions to establish programs for compliance with the Bank Secrecy Act and Treasury's regulations. When I last wrote to you, I indicated NCUA would provide further guidance in this area. NCUA's guidelines are attached. The guidelines are in three parts. Part I is a checklist of the Treasury requirements and Part II is a more detailed explanation. Part III contains suggestions for establishing your compliance program.

While we have made every effort to keep the guidelines as concise as possible, the requirements of the law and Treasury's regulations are lengthy and complex. The guidelines do not impose new requirements, but rather are intended to help you comply with the law and regulations.