Garden Savings FCU Consents to C&D for BSA Violations

ALEXANDRIA, Va. — Garden Savings Federal Credit Union has agreed to a Cease & Desist Order from NCUA, without admitting or denying fault, for Bank Secrecy Act noncompliance, the regulatory item credit unions often cite as the most onerous.

The administrative order, unanimously approved by the NCUA Board July 3, states that the credit union has agreed to contract an outside audit firm within 60 days of the order, signed June 25 by most of the credit union’s board, to correct deficiencies; complete a risk assessment; keep a list of high and moderate risk members; file all missing Currency Transaction Reports and Suspicious Activity Reports as well as the back CTRs for improperly exempted businesses within 30 days; establish written high-risk member policies and procedures within 90 days; hire a “competent, full-time” BSA compliance officer and approve a job description for the BSA officer within 90 days; ensure necessary training of the BSA officer; obtain and research all FinCEN 314(a) information sharing within 14 days of the request; establish a training program within 90 days; implement and maintain adequate internal controls; and ensure Office of