AML & Compliance Policy
Anti-Money Laundering & Know Your Customer Compliance
Regulatory Compliance
BSA/AML • FinCEN • FATF Guidelines
KYC Verification
Identity verification for all accounts
Transaction Monitoring
24/7 automated suspicious activity detection
1. Our Commitment to AML Compliance
Northvane Financial Credit Union is committed to full compliance with all applicable anti-money laundering (AML) laws and regulations. We maintain a comprehensive AML program designed to detect, prevent, and report suspicious financial activity in accordance with the Bank Secrecy Act (BSA), FATF recommendations, and all applicable jurisdiction-specific regulations.
2. Know Your Customer (KYC)
All account applicants must complete our KYC verification process, which includes: • Government-issued photo ID verification (passport, driver's license, national ID) • Proof of address (utility bill, bank statement less than 3 months old) • Source of funds declaration for deposits exceeding $10,000 • Enhanced Due Diligence (EDD) for high-risk customers or politically exposed persons (PEPs)
3. Transaction Monitoring
Our automated systems monitor all transactions in real-time for: • Unusual transaction patterns inconsistent with account history • Transactions involving high-risk countries or sanctioned entities • Structuring (breaking large transactions into smaller amounts to avoid reporting) • Rapid movement of funds through accounts • Cash-intensive business transactions above reporting thresholds
4. Suspicious Activity Reporting (SAR)
We are legally required to file Suspicious Activity Reports (SARs) with FinCEN for transactions that: • Involve funds from illegal activity • Are designed to evade reporting requirements • Lack a lawful purpose • Involve transactions of $5,000 or more that trigger suspicion. SARs are filed confidentially and customers must not be notified ("tipping off" is prohibited).
5. Currency Transaction Reports (CTR)
We file Currency Transaction Reports for all cash transactions (deposits, withdrawals, exchanges) exceeding $10,000 in a single day. Structuring transactions to avoid this threshold is a federal crime.
6. International Transfer Compliance
All international wire transfers are subject to: • OFAC sanctions screening • Correspondent bank AML requirements • Country risk assessment • Enhanced monitoring for transactions to/from high-risk jurisdictions • SWIFT gpi compliance for tracking and transparency
7. Customer Due Diligence (CDD)
We apply risk-based due diligence to all customer relationships: • Standard CDD for regular retail customers • Enhanced Due Diligence for high-net-worth individuals, complex transactions, or high-risk jurisdictions • Ongoing monitoring and periodic account reviews • Beneficial ownership identification for business accounts
8. AML Training
All staff receive mandatory AML training covering recognition of money laundering red flags, internal reporting procedures, customer due diligence requirements, and regulatory updates. Training is conducted annually and upon onboarding.
9. Sanctions Compliance
We screen all customers and transactions against OFAC SDN lists, EU sanctions lists, UN Security Council sanctions, and jurisdictional blacklists. Matches result in immediate account suspension and regulatory reporting.
10. Compliance Officer
Our designated Bank Secrecy Act (BSA) Officer oversees all AML activities. For AML-related concerns or to report suspicious activity, contact: customercare@northvanecu.online