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Compliance Specific News & Resources for GoWest Credit Unions
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Compliance Newsletter

COMPLIANCE HEADLINES



National Credit Union Administration (NCUA) 



NCUA to Host Strategic Plan Town Hall on Sept. 9 


The NCUA will host a Strategic Plan Town Hall on Sept. 9 starting at 2 p.m. Eastern. The virtual event invites credit union industry stakeholders to provide input on the 2026-2030 NCUA Strategic Plan. Attendees are encouraged to share their ideas on how to strengthen the credit union system, highlight future issues impacting credit unions, and provide feedback on what they would change about the most recent NCUA Strategic Plan. 


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Consumer Financial Protection Bureau (CFPB) 



Proposed Rule of Legal Standard Definition for Supervisory Proceedings for Nonbank Supervised Entities 


The CFPB published a proposed rule which would define ‘‘risks to consumers with regard to the offering or provision of consumer financial products or services’’ that the Bureau will use in proceedings to designate nonbank covered persons for CFPB supervision. 


Conduct that poses risks to consumers regarding the offering or provision of consumer financial products or services consists of conduct that:  


  • Presents a high likelihood of significant harm to consumers; and  

  • Is directly connected to the offering or provision of a consumer financial product or service. 

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Financial Crimes Enforcement Network (FinCEN) 



FinCEN Issues Advisory and Financial Trend Analysis on Chinese Money Laundering Networks 


To raise awareness about Chinese money laundering networks (CMLNs), FinCEN is issuing: (1) an Advisory to urge financial institutions to be vigilant in detecting the use of CMLNs by Mexico-based drug cartels, including several designated as Foreign Terrorist Organizations; and (2) a Financial Trend Analysis (FTA) highlighting the scope and breadth of CMLN activity in the United States. 


Bank Secrecy Act Reports Highlight Breadth of Chinese Money Laundering Networks in the United States 


  • As discussed in the FTA, FinCEN analyzed 137,153 Bank Secrecy Act (BSA) reports filed by financial institutions between January 2020 and December 2024 (the dataset) associated with suspected CMLN-related activity, totaling approximately $312 billion in suspicious transactions. 

  • CMLNs, as discussed in the Advisory and FTA, play a significant role in laundering proceeds from drug trafficking. CMLNs are also involved in facilitating a range of additional illicit activity, including fraud, human trafficking, and human smuggling. 

  • Private individuals carrying passports from the People’s Republic of China (PRC) play a significant role in these networks and may wittingly or unwittingly assist CMLNs launder money on a global scale. 


CMLNs Are Being Utilized by Cartels to Launder Illicit Proceeds


  • CMLNs are professional money launderers and are heavily utilized by Mexico-based cartels to launder drug proceeds in the United States. 

  • The business relationship between CMLNs and Mexico-based drug cartels is driven in part by laws passed by the Government of Mexico and the PRC that restrict financial flows. 

  • Mexico’s currency restrictions prevent large amounts of U.S. dollars from being deposited into Mexican financial institutions, hindering the cartels’ ability to launder funds through the formal Mexican financial system. The PRC’s currency control laws limit the amount of money Chinese citizens can transfer abroad each year. 

  • U.S.-based CMLNs may sell U.S. dollars purchased from Mexico-based drug cartels through advertisements on social media or by leveraging personal networks involving Chinese citizens and/or businesses seeking to evade the PRC’s currency control laws. 

  • Ultimately, Chinese citizens’ demand for large quantities of U.S. dollars and the cartels’ need to launder their illicit U.S. dollar proceeds has resulted in a mutualistic relationship wherein the cartels sell off their illicitly obtained U.S. dollars to CMLNs who, in turn, sell the U.S. dollars to Chinese citizens seeking to evade China’s currency control laws. 


CMLNs Are Involved in Other Types of Illicit Activity 


  • Financial institutions filed 1,675 BSA reports in the dataset indicating suspicious activity potentially involving human trafficking or human smuggling. 

  • Financial institutions filed 43 BSA reports in the dataset involving approximately $766 million in suspicious activity, on 83 adult and senior day care centers, all of which listed addresses in New York. 

  • FinCEN also identified 108 BSA reports in the dataset involving deposited funds potentially associated with healthcare fraud, elder abuse, and suspicious gaming activity. 


CMLNs Use a Variety of Methods to Launder Proceeds, and May Recruit Employees Inside Financial Institutions 


  • To launder illicit cartel funds, CMLNs often utilize trade-based money laundering, money mule, and mirror transaction methodologies. 

  • CMLNs may recruit financial institution employees to act as complicit insiders or infiltrate and place CMLN members within a financial institution to assist in CMLN operations. 

  • CMLNs may also provide money mules with counterfeit Chinese passports to facilitate account opening and engage in other illicit financial behavior. 


CMLNs Are Potentially Facilitating Real Estate Purchases Funded by Illicit Proceeds from a Variety of Financial Crimes 


  • Financial institutions filed 17,389 BSA reports in the dataset associated with more than $53.7 billion in suspicious activity involving the real estate sector. 

  • CMLNs may use money mules or shell companies to purchase real estate, which may serve as an investment for the CMLN or a wealthy China-based client of the CMLN. 

  • CMLNs potentially play a key role in laundering illicit funds through U.S. real estate by using complex, layered transactions; involving third parties; and ultimately, integrating illicit proceeds into the real estate sector to launder ill-gotten gains. 

  • CMLNs potentially target high-value markets and leverage Chinese investors who have strong interest in U.S. real estate. 


FinCEN is Issuing Key Indicators of Illicit Activity linked CMLNs to Alert Financial Institutions 


  • FinCEN has identified red flags to help financial institutions detect, prevent, and report suspicious activity connected to CMLNs laundering illicit proceeds. 

  • In situations where the money mules are opening accounts, these money mules may report their occupation during the account onboarding process as “student,” “housewife,” “retired,” “laborer,” or other occupations that typically do not engage in large volumes of transactions, which may bring about suspicions as to why these accounts have large volumes of unexplained wealth. 

  • Please read the full advisory for a comprehensive list of red flag indicators. 


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Federal Trade Commission (FTC) 


Telemarketing Sales Rule Fees 


The FTC issued a final rule which will increase the fees charged to entities accessing the National Do Not Call list. The revised rule increases:  

  • The annual fee for access to the Registry for each area code of data from $80 to $82 per area code, and  

  • The maximum amount that will be charged to any single entity for accessing area codes of data from $22,038 to $22,626.  


Entities may add area codes during the second six months of their annual subscription period, and the fee for those additional area codes increases from $40 to $41. 


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Internal Revenue Service (IRS) 


Interest rates remain the same for the fourth quarter of 2025 


The IRS has announced that the interest rates will remain the same moving into the fourth quarter of 2025 beginning Oct. 1. Currently the rate for overpayments and underpayments is 7% annually and compounded daily for individuals. Per the Internal Revenue Code, the rate of interest is determined by the federal short-term rate plus 3% points. The current rate is based on the short-term rate determined in July 2025. 

   

League InfoSight Highlight



CFPB Seeks Input on Personal Financial Data Rights Rule Rewrite 

  

As previously reported, the CFPB indicated in a July 29th court filing that it planned to engage in an “accelerated rulemaking process” to rewrite its personal financial data rights rule finalized in October 2024. That process has now begun. 

  

The agency published an advance notice of proposed rulemaking (ANPR) in the Federal Register on Aug. 22 seeking comment on four specific issues it plans to address in the rewrite: 


  • The Dodd-Frank Act permits a consumer and/or representative acting on behalf of the consumer to request covered data from a financial institution. The CFPB seeks comments on who should be allowed to serve as a representative acting on behalf of the consumer.  

  • Under the final rule in its current form, a financial institution is prohibited from imposing any fee and/or charge on a consumer when fulfilling an information request. The ANPR asks whether the Dodd-Frank Act specifically requires this, and if so, what steps a financial institution should be allowed to take to defray some of its costs associated with fulfilling the information request.   

  • The final rule requires financial institutions to have appropriate safeguards in place to protect against malicious actors in the use, retention, and transmission of consumer financial data. The CFPB seeks comment as to whether the final rule’s information security standards go far enough.  

  • The final rule requires a financial institution to obtain express informed consent from the consumer before making his/her consumer financial data available to a third-party. The ANPR seeks comment as to whether the rule, in its current form, provides adequate consumer privacy protection.  

  

Comments to the ANPR, available here, must be received by Oct. 21, 2025. 


New Credit Union Fraud Risk Assessment Available in InfoSight360 


InfoSight has released an updated Credit Union Fraud Risk Assessment within InfoSight360 under the Additional Resources of the Risk Management section under the Fraud topic. 


The risk assessment serves as a template for credit union in performing a fraud risk assessment and covers key areas that credit unions may experience fraud in and then can be used to establish controls to mitigate the various risks. 





ARTICLES OF INTEREST


Buy Now Pay Later (BNPL) and Loan Underwriting Considerations 


U.S. Department of Labor Promotes AI Literacy Across the American Workforce 


What is Included in the Remittance Transfer Tax? 


SCAM UPDATES



LA Fitness made it difficult for people to cancel gym memberships, FTC says 


That social media ad with super low prices on well-known brands could be a scam 


How to Avoid Scams When Looking for Drug Treatment 



COMPLIANCE CALENDAR

Sept. 4, 2025: CFPB Cognitive Decline and Financial Exploitation in Older Age Webinar 


Sept. 9, 2025: NCUA Virtual Strategic Plan Town Hall 


Sept. 18, 2025: FDIC, FRB, Treasury, OCC – Request for Comment on ways the agencies can take action collectively or to help consumers, businesses, and financial institutions mitigate check, automated clearing house (ACH), wire, and instant payments fraud.


Sept. 30, 2025: Federal Benefit Payment Checks No Longer Issued 


Oct. 1, 2025: Quality Control Standards AVMs 


Oct. 21, 2025: CFPB Comments Due ANPR on Open Banking Rule


Dec. 30, 2025: CFPB: Overdraft Lending: Very Large Financial Institutions (Over $10 Billion)


Jan. 1, 2026: NCUA – Succession Planning Effective Date


March 1, 2026: CFPB: Residential Property Assessed Clean Energy Financing (Reg Z) 


March 20, 2026: NACHA Risk Management Topics – Company Entry Descriptions 


March 20, 2026: NACHA Risk Management Topics - (Fraud Monitoring Phase 1) 


April 1, 2026: Compliance Date – CFPB Personal Financial Data Rights for Credit Union’s Over $10 Billion in Assets 


June 19, 2026: NACHA – Fraud Return Reason Code


July 1, 2026: CFPB – Small Business Lending Data – ECOA


Dec. 12, 2026: NCUA Simplification of Share Insurance Effective Date 



TOOLS & RESOURCES

Effective Dates
Bulletins & Alerts
Webinar Calendar
AffirmX and GoWest Partnership

Q&A OF THE WEEK

Are we required to send a change in terms notice if we are increasing the cost to members for ordering a replacement debit card? 


Yes. Under Reg E, if you increase a cost that the consumer must pay associated with an “access device”, you must provide a change in terms notice. 



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If you have questions about this communication, contact us at 800.546.4465 or via our shared email inbox at compliance@gowest.org.

Your GoWest Compliance Team, 

David Curtis

CUCE

Director, Compliance Services
P: 206.340.4785

Tiarra Sanders-Hausa

NCCO

Manager, Compliance Services

P: 206.618.9302

Copyright © 2025 GoWest Credit Union Association. All Rights Reserved.

Mailing Address:
GoWest Credit Union Association, 18000 International Blvd Ste. 1102, SeaTac, WA 98188, United States
1.800.995.9064

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