31 THE NAFCU JOURNAL MAY–JUNE 2022 Soto also views the proposed enhanced feedback on the use of SAR information that FinCEN and the U.S. Department of Justice or local law enforcement find helpful to be promising. “The current trends published by FinCEN are helpful, but people outside the compliance arena might find more detailed information helpful,” she said. The ability to share specific information that law enforcement finds beneficial will enhance front-line team member training by showing how their efforts to identify suspicious activity are about more than just complying with the law, she added. The increasing use of digital assets and convertible virtual currency (CVC) poses a higher potential for suspicious activity. According to NAFCU’s October 2021 Economic & CU Monitor survey, about 48% of respondents reported some degree of scrutiny from an examiner regarding CVC transactions, ranging from a minimal level to moderate level of scrutiny. In a letter to FinCEN regarding the review of BSA regulations and guidance, NAFCU asked for greater transparency regarding the monitoring of cryptocurrency transactions and sufficient guidance so credit unions can incorporate the priority into their risk assessments. The emphasis on virtual currency and blockchain technology will be a challenge for many credit unions, depending on how FinCEN guidance develops, said Stephanie Painter, BSA manager, DuPont Community Credit Union. “I’m 30-years-old and grew up with technology, but there is a steep learning curve
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