Does the BSA Compliance Officer need to be an employee of the entity it serves. Wwe have an affiliate that requires a BSA Compliance Officer but I don't actually work for that affiliate. I am already Compliance Officer at the CU.

All FI are required to have a BSA Officer

It does not have to be an employee. I'm not familiar with the employee sharing provisions in CU's. Normally, the affiliate would have to pay a reasonable fee for the provision of services between affiliates.

Thank you. I will research the sharing issue.

Because of the high confidentiality issue, why would you NOT want it to be an employee of the bank? Contract would have to be VERY specifically laid out otherwise.

I personally would not go there unless I had to due to the risk.

WM

I've seen it where the BSA Officer is actually the employee of the parent or holding company. Since they are usually high-level employees they are privy to all of the same information / systems and often have more information (thinking from a due diligence standpoint) than the bank employee.