NCUA orders BSA and recordkeeping fixes at Inter-American Federal Credit Union
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NCUA's 2022 consent order required a Brooklyn credit union to fix BSA, OFAC, and reconciliation gaps without admitting the underlying findings; it was liquidated in 2023.
What happened
In May 2022, Inter-American Federal Credit Union, a small federally chartered credit union in Brooklyn, New York, signed a stipulation consenting to a cease-and-desist order from NCUA’s Eastern Regional Office. NCUA announced the order publicly at the end of June 2022, as part of its regular monthly enforcement-actions release.
The order required the credit union to fix a list of specific problems within set deadlines, including: gaps in suspicious activity monitoring and reporting, deficient Bank Secrecy Act staff training, missing written OFAC screening procedures, unreconciled corporate accounts, out-of-balance conditions in loan, share, and cash accounts, incomplete independent verification of member accounts, and non-compliance with New York’s dormant-account escheatment requirements. Most deadlines in the order fell on June 30, 2022, and the credit union was also required to obtain a CPA audit report covering roughly August 2017 through March 2022.
The stipulation includes a standard no-admission clause. The credit union agreed to the corrective steps to resolve the matter but did not concede that NCUA’s underlying grounds for the order were accurate, apart from acknowledging NCUA’s jurisdiction over the case.
NCUA’s press releases do not explain what triggered the examination that led to the order, and no further public detail on the underlying findings has been located.
Where it stands
The cease-and-desist order was resolved by consent in 2022 — this is a settled matter, not an unproven allegation, and the credit union’s agreement to it did not include an admission of wrongdoing.
Separately, NCUA placed Inter-American Federal Credit Union into involuntary liquidation on March 8, 2023, stating only that the credit union was not operating in a safe and sound manner. NCUA’s liquidation announcement does not draw an explicit line between the 2022 order and the 2023 liquidation, and this page does not assume one. The two events are reported here in sequence, not as cause and effect. At liquidation, the credit union held about $727,157 in assets and served roughly 460 members; all insured shares were covered through the National Credit Union Share Insurance Fund. With the credit union no longer operating, no further developments in this specific matter are expected.
Questions this raises for your committee
The order’s list of required fixes reads like a checklist of core internal-control areas — SAR monitoring, BSA training, OFAC procedures, account reconciliation, member account verification, dormant-account handling — that show up at credit unions of any size, not just very small ones. The questions above are written for your own committee, not as a claim about what this credit union’s committee did or didn’t do; nothing in the public record describes that committee’s activity.
Timeline
- 2022-05-31 Inter-American Federal Credit Union signed a stipulation and consent to a cease-and-desist order with NCUA's Eastern Regional Office.
- 2022-06-30 NCUA publicly announced the cease-and-desist order as part of its monthly enforcement-actions release. [2]
- 2023-03-08 NCUA placed the credit union into involuntary liquidation, stating it was not operating in a safe and sound manner. Members' insured shares were covered by the National Credit Union Share Insurance Fund. [3]
Questions this raises for your committee
Does your credit union's BSA officer have a documented process for deciding when a suspicious activity report gets filed, and does anyone outside that officer's own chain periodically review a sample of the decisions not to file?
Suspicious activity monitoring and reporting is one of the areas the order required the credit union to fix. A single person's judgment call on SAR filings, with no independent check, is a common gap at small institutions.
Who reconciles your credit union's general ledger and corporate accounts each month, and does someone independent of that person review the reconciliation before it's considered done?
The order also cited out-of-balance conditions across loan, share, and cash accounts. Unreconciled accounts are exactly the kind of thing a supervisory committee's audit function exists to catch before they compound.
Does your credit union have written OFAC screening procedures, and has anyone tested them against a sample of recent transactions or new memberships in the last year?
OFAC compliance is often treated as a subset of 'BSA stuff' handled entirely by one compliance function. Testing it separately, even briefly, is one way a committee can confirm the procedures exist in practice and not just on paper.
Does your credit union have a documented process for escheating dormant accounts to your state within the required timeframe, and does your committee ever see a report on it?
Dormant-account handling was another item named in the order. It's a low-visibility process — no member is watching it happen — which is exactly why it benefits from a periodic, independent look.
Sources
- primary Stipulation and Consent to Cease and Desist Order, In the Matter of Inter-American Federal Credit Union (Docket 22-0112-ER) — National Credit Union Administration, 2022-05-31
- primary NCUA Issues Enforcement Orders in June 2022 — National Credit Union Administration, 2022-06-30
- primary Inter-American Federal Credit Union Closes — National Credit Union Administration, 2023-03-08
- secondary NCUA barred two people in June, issued one cease-and-desist — American Banker (Credit Union Journal), 2022-06-30
- secondary NCUA Liquidates Inter-American Federal Credit Union — CU Times, 2023-03-09
Update log
- 2026-07-23 Page created after reviewing NCUA's administrative order and related press releases.
This is not legal, accounting, or compliance advice. Verify against the official source and your own professional advisors.