Live Life Federal Credit Union
Outcome
NCUA issued a cease and desist order against Live Life Federal Credit Union for BSA/AML failures including inadequate automated transaction monitoring, deficient marijuana-related business (MRB) account oversight, delayed SAR filings, inaccurate Currency Transaction Reports, and an unreviewed Money Services Business program; the credit union was ordered to terminate its MSB program and cease opening new MRB accounts.
Details
Live Life Federal Credit Union — BSA/AML and Marijuana-Related Business Compliance Failures (2019–2021)
Outcome: NCUA issued a consent cease and desist order (Docket 21-0105-ER) requiring Live Life Federal Credit Union to terminate its Money Services Business program by March 15, 2021, cease opening new marijuana-related business accounts, implement automated transaction monitoring systems, and correct deficient Currency Transaction Report and Suspicious Activity Report practices.
Live Life Federal Credit Union, located in Fraser, Michigan, was the subject of a 2021 NCUA administrative cease and desist order addressing a constellation of BSA/AML failures. The credit union had taken on two categories of high-risk accounts — marijuana-related businesses and money services businesses — without the compliance infrastructure to manage either category properly.
The automated transaction monitoring failure was foundational. The credit union lacked a system capable of effectively monitoring all transactions to identify suspicious activity, as required by the Bank Secrecy Act. Without automated monitoring, the credit union could not reliably detect structuring, unusual transaction patterns, or activity meeting SAR filing thresholds.
The marijuana-related business (MRB) compliance failures were multidimensional. FinCEN's 2014 guidance on MRB accounts (FIN-2014-G001) requires financial institutions serving cannabis businesses to conduct enhanced due diligence including: verifying state licensure, reconciling point-of-sale data against deposit activity, and monitoring for activity inconsistent with the business's licensed activities. The NCUA found that Live Life's MRB monitoring program failed to meet these requirements.
The credit union's Money Services Business program was operating without any suspicious activity review — a fundamental requirement for financial institutions banking any business that itself facilitates money transmission. The order required the program to be terminated entirely by March 15, 2021.
Currency Transaction Reports were found to be inaccurate, and SAR filings were delayed, indicating systemic failures in the cash reporting and suspicious activity identification processes. The order required all FinCEN "Red Flags" to be monitored and SARs to be filed immediately in accordance with applicable regulations.
Primary Source: NCUA Administrative Order — Live Life Federal Credit Union
How Crucible Prevents This
A marijuana-related business compliance program with documented point-of-sale data reconciliation, licensure verification, and unusual activity thresholds would have provided the evidence trail the NCUA found absent. Automated CTR generation integrated with the core system would have prevented inaccurate Currency Transaction Reports. A formal MSB onboarding and monitoring protocol requiring board-level approval would have either prevented the unreviewed MSB program or ensured it was properly supervised.
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