What action must a credit union take when new lists under program 314(a) are posted?

When new lists under program 314(a) are posted, the correct action for a credit union is to query their records for data matches. This is essential because the 314(a) program, established by the USA PATRIOT Act, allows law enforcement agencies to identify individuals and entities that may be involved in money laundering or terrorist financing. Credit unions and other financial institutions are required to review their customer records against these lists to determine if they have any accounts or transactions that may involve the individuals or entities specified in the updates.

By querying their records, the credit union can proactively identify potential risks and fulfill their obligations under BSA (Bank Secrecy Act) compliance regulations. This action helps in maintaining the integrity of the financial institution and preventing potential illicit activities, ensuring that they remain compliant with legal and regulatory standards. Ignoring the updates or failing to take appropriate action could result in significant legal liability and regulatory penalties for the institution, as they would not be fulfilling their due diligence responsibilities.