Will credit unions be held responsible for the MSB's BSA/AML program?

The assertion that credit unions will not be held responsible for a Money Services Business (MSB)'s BSA/AML program is correct. Credit unions, while involved in facilitating transactions with MSBs, are not directly responsible for the implementation or execution of an MSB's own BSA/AML compliance program. The MSB itself bears the primary responsibility for adhering to BSA/AML regulations, as it is the entity operating in that capacity and engaging in financial activities that require such compliance measures.

Credit unions must maintain their own BSA/AML compliance programs to manage their legal requirements and risks associated with transactions involving MSBs. However, they are required to conduct due diligence and understand the nature of their relationships with MSBs. This includes assessing the risks involved in transactions and monitoring those dealings, but their level of accountability does not extend to the oversight of the MSB's compliance efforts.

While related to transactions and potential risks, the responsibility for a separate entity's compliance (the MSB) primarily remains with that entity, not with the credit union. This delineation is crucial in understanding the roles financial institutions play in the larger regulatory framework, particularly regarding compliance with BSA/AML laws.