LAS VEGAS — Art Dinger, corporate compliance officer at Pennsylvania State Employees Credit Union in Harrisburg, says he knows something about how to “put a smile on the faces of examiners” looking at BSA documents.

“Just make sure you have a policy and procedures approved by the board and they are in writing,” declares Dinger, a speaker at the special Dec. 14-15 Credit Union Times/Executive Enterprise Institute compliance seminar here. Too many CUs, he told seminar attendees, fail to develop cohesive BSA policies on risk assessment, SARs or CTRs, and instead “simply have partial procedures” which are not properly documented. The 9/11 attacks, Dinger said, “changed everything on BSA,” breathing new life into PSECU programs as he recalled the difficulty then “of even finding uniform policies.” Once they were collected, “we decided to put them all together in written form and it has worked well for us,” he said. Responding to questions during his presentation entitled, “Creating an Effective Anti-Money Laundering Program”, Dinger said PSECU does go out of its way to train the CU board on BSA since they are the ultimate body that must know staff actions. “But we don't go in depth on any of it” he said unless it is warranted, but the overall goal is to assure directors “that we are complying.” –[email protected]