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A sampling of articles and Guru Q&As relating to anti-money laundering, anti-terrorism, the Bank Secrecy Act, enhanced due diligence, OFAC, and the USA PATRIOT Act.

Articles

AML/Customer Identification

Recordkeeping of CIP Information
Cedular Card
CIP - Valid ID Number
Identifying information
CIP – POA & Legal Capacity of Incarcerated Person
The Current Economic Crisis and New Accounts
Opening Business Accounts
CIP & IOLTA Accounts
Old Customer, New Signature Card. CIP Required?
Required to Open Account for Prisoner?
CIP Verification Checklist - Commercial Borrowers
CIP - IRAs & HSAs
UTMA Ownership
CIP Documentation - Court Ordered Accounts
Crime in Progress
Adverse Action List for the Examiner
Unfamiliar Forms
Government Agents/Employees Exempt from CIP?
Update Existing & Merged Customer CIP Information
The Amish & Non-Interest Bearing Accounts
Pre-CIP Accounts
Can We Combine our BSA, OFAC & CIP Policies?
Patriot Act & CIP - Minor Identification
Using Existing CIP Procedures to Verify Identity
Customer Identification Programs
CIP Notice Verbiage
CIP Documentation & Sole Proprietorships
Insurance Companies and Anti-Money Laundering
Gift Cards - Monetary Instruments?
Government Lists for 314a Search Requirements
POA CIP Requirements
Effective Date of CIP Physical Address Rule
When must a Casino file a Currency Transaction Report (CTRC)?
Casinos Compliance with BSA/AML legislation and the MLSA
Bank Secrecy Act Requirements for Money Services Businesses
BSA/AML/Patriot Act Applicable to Trust Co?
Is Our BSA/AML Risk Assessment Adequate?
CIP Requirements & Foreign College Students
Interagency BSA (Bank Secrecy Act) Guidance
CIP - College Student Physical Addresses
Setting Scoring Thresholds Based on Risk for Automated Customer Identification Program (CIP) Screening Software Tools
Requirements- 4 Basic Criteria on all Signers?
CIP on Authorized Signer
CIP on Safe Deposit Box Signer
CIP - Logical Verification
ID and Re-ID for CIP?
Opening Accounts for New Amish Customers
CIP - Indian Tribe Account
CIP Notices on State Chartered CU's Website
CIP & OFAC Record Retention Guidelines
USA PATRIOT Act ID Verification on the Other Owner
ID for the Patriot Act
Opening an Account with a Puerto Rican ID
Former Customer Opens Account, No CIP?
Consequences of AML Non-Compliance
Guru Chatter on CIP and IDs (PDF)
MSB Risk Assessment on Business Loan Customers?
Do We CIP Minors?
Is this Structuring?
TIN Requirements on Foreign Accounts
CIP - ID Documents for Joint Account Holder
How Do we CIP New Internet Banking Customers?
Which States Prohibit Credit Cards as ID for CIP?
Prepaid funeral trusts and CIP
CIP Rules for ID
CTRs: Documenting ‘Known’ Customers
Is He an Established Customer for Purposes of CIP?
Bank of New York Pays to Avoid Criminal Charges
Providing Services to MSBs
Guru Charter on BSA - 04/05
AML Certification in United Arab Emirates
Anti-Money Laundering Has Come A Long Way
CIP and Government Request Procedures
Matricula Consular as primary ID for CIP?
Native Americans and CIP Requirements
Retention of OFAC and 314a Records
Documenting a BSA Exemption
AML Policies, Procedures for an MSB
AML Requirements Upon Identifying an MSB
Tricks to Identify High-Risk AML Accounts
Need Help with MSB Requirements
Guru Compilation: CIP (PDF)
Section 326 Takes Over: "The Devil Is In The Details"
One 326 Problem
Risk Assessment Challenge: How Much Risk is "Reasonable and Practicable?"
Check Cashiers CIP Requirements
CIP Use of a P.O. Box for Mail
CIP Rules Define 'Customer'
CIP on a Recurring But Closed Customer
Retaining I.D. in CIP loans
CIP record retention
CIP & SSN Verification
CIP & IRAs
CIP & Purchased Loans
CIP: Is a guarantor a customer or a non-customer?
CIP Record Retention
Changing Signatures on CDs for CIP
Posting CIP Notices in Branches
Section 326: Where is the government list?
AML Certificate Number
Why Require a TIN for an Irrevocable Trust?
CIP and Savings Bonds
Explicitly Mentioning the PATRIOT Act on Lobby Notices
Obtaining Identifying Info for Old/New Customer
CIP and the High Risk Customer
CIP and a UTMA Account
Verifying Residence Address
Photocopying SS Cards
Prohibitions on Copying Driver's Licenses
How can I establish a compliance program in response to
the USA PATRIOT Act?

CIP and ATM/Debit Card Accounts
CIP on Construction Loan
BSA Enforcement
Explaining Suspicious Activity
Where to Include the ID Section
Fraud Database In The Works
314(a) Search Request Questions
Existing Customer vs. Former Customer
CIP and Denials
PATRIOT Act: Section 312, PEPs, and Senior Foreign Political Figures
Money-Laundering or Terrorism: What Are We Looking For?
Training on ID Verification and Spotting Fakes
ACTION AUDIT
Putting "See ID" on back of card
Passports and U.S. Citizens
CIP Record Retention Requirements
The MATRICULA CONSULAR: BIG Problem - Accept It Or Not?
Penalties for CIP Violations
Tips for Ensuring an Effective Anti-Money Laundering Program
CIP and Savings Bonds
KYC vs. CIP
CIP and Indirect Lending
CIP and Guarantors
CIP and Business Loans
CIP Procedures, Guarantors, and Co-borrowers
CIP & Purchased Loans
CIP and Rural Addresses
Fines for CIP Noncompliance
CIP and Shareholders
CIP and Birthdate Info on Loan Apps
CIP and Public Records
CIP: Requesting By-Laws
Loan Apps and CIP Changes
CIP and Credit Reports
CIP Notices to Loan Customers
CIP and Trust Customers
CIP & SSN Requirements
Combining the Patriot Act Disclosure with the Privacy Policy Disclosure
Using Credit Reports to Satisfy CIP Requirements
Spotting High Risk Clients
Using Your Old KYC Policy To Create Your New CIP
OFAC: The New Compliance Hot Seat
Handling a Customer Who Refuses to Update Signature Card
Verification & Restricting Account Access
CRA & AML Employee Handbook Information
Documents Required To Open A Business Account
Non-Customers & CIP
CIP & Mortgage Lenders
How to choose KYC software - by World Compliance
Online Loan Applications, Disclosures, and CIP
Evaluating Fraud and PATRIOT Act Solutions
CIP: Record Retention For Business Account Information
CIP: Verifying Student Loans
BSA TIN Requirement & Religious Beliefs
What's the difference between KYC & CIP?
Online Activities & CIP
Lending and Customer Identification Programs: An Introduction - by BOL Guru Ken Golliher
Q&As on CIP - by BOL Guru David Dickinson
CIP Customer Notice Sign Size Requirement
CIP - Excluding a "Person with an Existing Account" - by BOL Guru Ken Golliher
Audio Blog by Ken Golliher on where the real resistance is to asking existing customers for identification.
Your Bank's "Location" and CIP - by BOL Guru Ken Golliher
CIP FINAL RULES: 10 Quick Changes
CIP Final Rules -- A White Paper from Attus
The Identity Validation Conundrum
Identity Theft
Retaining ID On Customers
Adequate Advance Notice Under Section 326
Non-Resident Signer With No SSN
Who are you?
USA PATRIOT Act: CIP & Photocopying The Driver's License
Updating BSA Policies To Accommodate Section 326 Rule
USA PATRIOT Act: ID Requirements For A Minor
CIP Compliance Delayed
CIP Program Implementation Deadline
ID Theft - Real Cases
USA PATRIOT Act Identification Requirements
Proposed Rules on Customer ID Just Issued
Anti-Money Laundering Program
Fighting Money Laundering: The Next Steps
The 120 Hour Rule
Sixty Second Solution: Identifying Business Customers -- Note: You must be using Internet Explorer when you click this link. Uses Windows Media Player.
BSA/OFAC Lessons from Enforcement Actions
Another Mystery Man
ID Requirements for New Accounts
Fighting Back on Identity Theft
Information Sharing: Should You Certify?
PATRIOT Act AML Rules
AML Policy Requirement
AML Program vs. BSA Program
AML and Community Banks
Money laundering Contact Person
Identity Fraud
Online Obits Used To Fight ID Theft
FTC Cracks Down on Fake ID Sites
Anti-Money Laundering Compliance Top Of Regulator's List
How to Prevent Identity Theft
The Effects of Identity Theft
How Identity Theft is Committed
What is Identity Theft?
Steps to Protect Against Identity Theft
Security: Preventing ID Theft
Identity Theft Battle
see InfoVault, CIP

BSA
SAR Categories
CTR on Cashier’s Check
SARs and Robbery
Newly Acquired FI – Amending Customer Exemptions
SAR Filing – Who Makes the Call?
Willful Blindness
CTR Exemption Revoked – Report to FINCEN?
MSBs and the BSA
Amending BSA Policy
BSA Log - Convenience Signer Deposits
Law Enforcement & SAR Disclosures
Proof of BSA/AML and Compliance Training
BSA/AML Violations - Penalties/Prison Terms
Penalties for Not Filing SARs
Can We Combine our BSA, OFAC & CIP Policies?
Best Job Candidate for BSA Officer
SAR Filing – Time Limit
Customer Identification Programs
Complete a CTR & MIL?
IRS Requesting a Copy of a CTR
SAR Reporting on Forced Balancing
CTR on a Courier Service
Recording Transactions in a Monetary Instrument Log
BSA Training for IT & HR?
Documenting Business Activity without Filing SARs
SAR & CTR Required?
SAR - All the Deposit Details?
Account Closing Form Letter Due to SAR Filing
Exempt Customer Purchased by Non-exempt Company
Does this Add Up to a CTR?
Phase I Exemptions Permanently Exempted?
Inform Client of CTR Filing?
BSA Recordkeeping - Same Day Transactions Only?
Purchase of Monetary Instrument Under $3000
Unknown Depositor - CTR Filing
Not Renewing Exemption - FinCEN Notification
BSA Retention Policy & Loan Documents
Unknown Depositor - CTR Filing
Not Renewing Exemption - FinCEN Notification
CTR Reporting - Never Exempt
SAR Required on One Time Deposit or Withdrawal?
Exempting Once & Future Transactions
SAR Filing on Suspicious Activity Under $5000
When must a Casino file a Currency Transaction Report (CTRC)?
SAR'd Customer Eligible for a Phase II Exemption?
When must a Casino file a Currency Transaction Report (CTRC)?
New SAR Form Still on Hold?
BSA: What Your Peers Do and Say
BSA Compliance: Regulators are Playing for Keeps
Bank Secrecy Act Requirements for Money Services Businesses
BSA/AML/Patriot Act Applicable to Trust Co?
BSA Board Training
BSA Exemption - Cash for Vault Replenishment
Is Our BSA/AML Risk Assessment Adequate?
Structuring - SAR Filing & Board Notification
Would Customer’s Regularity Warrant a SAR?
CTR on Euros
HR 323 & CTR Exemptions of Seasoned Customers
Do We File a CTR When Multiple Checks are Cashed?
CTR - Customer Notification
HR 323 & CTR Exemptions of Seasoned Customers
CTR Pamphlet
SAR = Something Ain't Right
BSA: Report Change in Procedure to the Board?
CTR Completion Guidance
BSA Exemption List Removal
CTR Exemption Extends to New Business?
File a SAR In Lieu of a CTR?
15 Days to File a CTR - Calendar or Business Days?
File a SAR After Filing a CTR
Occupation "Retired"?
Co-mingled Funds
CTR Blank Guidance
CTR on a Night Deposit
Filing SARs & CTRs Online
Do We File a CTR on Another Bank?
Retention of Cashier's Check Log
Should Banks Develop an Exempt Persons List?
BHC Merging Banks -Refiling Current Exempt Persons
CTR on the Beneficiary of a Totten Trust
Cashing Payroll and Operating Account Checks, CTR?
Is this Structuring?
FinCEN Taps Bank for Penalty
BSA Training Is For Everyone!
CTRs When Deposit is to Joint Account
Reporting a Beneficiary on a CTR
CTR Required for Check Cashing
$3,000 Log, Include the Fee?
BSA: Should We Be Doing This?
What are the new BSA Examination Procedures for Customer ID Programs?
Possible Employee Structuring, SAR-able
The Best Way to File a SAR or a CTR
Concealing CTR Filing from the Customer
BSA Requirement: Identifying Currency on Deposit Tickets
BSA Exemption Biennial Filing Question
Accepting Accounts and Relationships
Exempt or SAR this Commercial Customer?
Filing a SAR for Payroll Fraud
Exempting a Foreign Owned Company
If It is a Bad SSN, Do We File a SAR?
SAR Reporting and Due Diligence
BSA Training Requirements
Guru Compilation: CTRs(PDF)
Guru Compilation: BSA (PDF)
Requiring an SSN is a Violation of Law, He Says
Cashier's Checks: Collecting Verification Info For Known Customers
Ongoing Reviews and SAR Follow-Up
Back-filing CTR Instructions
OTB Exemption for CTR Reporting
Reporting SARs to the Board or a Designee
Developing A Successful Bank Secrecy Program: To Catch A Crook, Think Like One
CTRs on Checks Cashed by Noncustomer Payee
Exchange and Deposit Totaling Over $10,000
Suspected terrorist: Beyond SAR, what steps to take?
Public Schools and CTR Exemptions
Activity History Needed for CTR Exemptions
Designation of Exempt Person
Completing CTR Correctly on Check Cashing
Completing a CTR for Aggregated Transactions
Understanding Multiple Transactions and CTRs
Format for CTR Form Submissions
Full Disclosure of SAR Content Examples of Recognizing Suspicious Activities
FinCEN Guidance on SAR Filings
Aggregating Deposits of Chain Restaurants
Completing a CTR on Two Deposits
Informing Customer of CTR
Verifying Nonprofit Organizations
BSA Enforcement: Expensive!
Giving a Customer a Copy of a CTR
Origin of Requirement for SAR Reports to Board
SARs on Nigerian Letters
SARs Oops
Noncustomer Purchase of Official Check
CTR Required for Cashing Loan Proceeds Check?
Smurfing
Naming BSA Officer in Your Policy
Getting a Copy of a CTR
FinCEN Expands E-Filing System: BSA Reports Can Now Be Filed Over Secure Internet
Retaining Records Regarding Forgeries
Automating The Case Management Process
Reportability of Cash Deposits into Two Accounts
Important Exception to BSA Rule Extended
BSA Exams: Lessons Learned by Experts
BSA Compliance Matters
Completing a CTR for Joint Account Deposits
Internal Theft & Filing SARs
New SAR Form and Software
Suspicious Activity & Stop Payments
CIP & SAR Filing Requirements
CTR, Exempt Person Form, and Reportable Transactions
Designing the BSA program to respond to risk
Tips for Ensuring an Effective Anti-Money Laundering Program
Using a Facsimile SAR
Are CTR Exemptions Mandatory?
Current CTR Form Expires?
Reopening Account Closed for Reg D Violations
Looking for a Reg Z Flowchart
CTRs & "Multiple Transactions"
CTR on an Estate Account
Training To File SARs
Filing SARs for Stopped Nigerian Scam
SAR Triggered by Invalid SSN?
Filing CTRs for Armored Car Currency Deliveries
CTRs & Split Deposits
Attorney-client Privilege & Filing a CTR
BSA Enforcement: Expensive!
BSA, Exempted Business Accounts, and Change of Address
Required BSA Records
Bank Secrecy -- Identification Information For CTRs
BSA: Wire Transfer Area Software
CTR Reporting: Aggregating Deposits & Withdrawals
Should we invest in a name matching software system?
Account transactions, BSA, and Documentation
Under BSA, what is a sub-account holder? SAR Slip-ups Result in CMP
What a BSA Officer Should Be Doing Now.
BSA: The Cost of a Compliance Program
Qualifications for a BSA Officer
Ineligible Businesses and BSA Exemptions
AML Program vs. BSA Program
No Shortcuts for Updating BSA Policy
CTRs for Wire Transfers?
BSA Audit Requirements
Board Approval for BSA Policy Changes
When Multiple Accounts Are Affected by a CTR Filing
One Tax ID, Multiple Accounts, and a CTR
CTR Filing Requirements: One Customer, Five EINs
CTR Penalty For Non-filing
Exempt Person Designation and Local Businesses
CTR Filing: Cashing On-us Checks For More Than $10,000
CTR Exemption For "Check Cashing" Store
BSA Brochure For Consumers
Recording "Purchased on behalf of" Information On MISLs and CTRs
Requirements: Exemption From CTR Filing
County Cash Deposits & CTRs
Exemption Lists For Correspondent Banks
Exemptions & CTR Filing Requirements
Can you inform the customer that you are filling out a CTR?
BSA: Recognizing What Is Suspicious
BSA Training: To Be Suspicious Or Not
BSA & Exempt Designation
FinCEN Issues More BSA Q&As
The Life and Times of a Currency Transaction Report
BSA and The Beatles -- A Training Exercise
The ABCs of BSA
BSA - Practice Makes Perfect
"Exempt Customers? No, We Don't Have Any."
Common BSA Violations
BSA, KYC: Staying Power

Control List
Using the FinCEN Information Request List
FinCEN List Nuts & Bolts
314(b) Information Sharing Update
Have the "Control Lists" been merged into the original OFAC lists?
Control List v. OFAC List
Obtaining The FBI Control List

OFAC
OFAC Policy & New International ACH Regs
OFAC Check - Non-customer Transactions
OFAC & Purchase of Cashier's Checks
How to Implement Risk-Based OFAC Monitoring Practices
How Banks Comply with OFAC Sanctions
Can We Combine our BSA, OFAC & CIP Policies?
Run an OFAC on Signers for a Lease Purchase
OFAC Check on Plan Beneficiaries
OFAC Screening & US Goverment Agencies
OFAC & Corporate Signers
Avoiding AML and OFAC Risks
The Bank of England (BOE) Watch List Has a New Name
Evolution of OFAC Guidance Since 1996
Updated OFAC Penalties, Fines and BIS Watch List Non-Compliance
OFAC - Credit Limit Increase
OFAC on Account Beneficiary
Voluntary Disclosure of OFAC Compliance Violations
Checking OFAC List When Wiring Funds
OFAC - Mexican Corporate Account Opening
Run Prospective Employees Against OFAC List
Advanced Matching Software Can Help Reduce False Positives
OFAC’s Multiple Watch Lists
OFAC on Payees that Bank is Paying
OFAC Check on Purchaser & Payee
OFAC Check on Cashier's Check Payee
OFAC Check on the Remitter
CIP & OFAC Record Retention Guidelines
OFAC Check on All Parties in a Wire Transfer?
Cash an On Us Check for Person on the OFAC List?
OFAC on the Beneficiary of a POD Account?
OFAC - Non-customer Check Cashing
BSA & OFAC - Loans Purchased From Another FI
Record Keeping of OFAC Screen Prints
OFAC Verification on Cashier's Checks?
Checking "PUPID" Wires Against the OFAC List
OFAC Sanctions & US Citizen Traveling in Iran
OFAC on a Third Party Check?
OFAC SDN List
Checking Insurance Clients Against the OFAC List
OFAC Check on Attorney in Fact
OFAC, IOLTAs & Non-Customer Beneficiary Tax ID#
OFAC - Record Retention
OFAC Checking of Loan Payments
OFAC List - Scanning ACH Origination Files
OFAC SDN Notification E-Mails
Dealing with positive OFAC matches
OFAC Requirements for Lenders
Possible match on OFAC - What to Do?
Retention of OFAC and 314a Records
Guru Compilation: OFAC (PDF)
OFAC SDN List
OFAC & mortgage broker loans
Checking the OFAC List on Cashier's Check Purchase
Help Arrives - Just In Time: Section 326 Compliance, OFAC Check and Fraud Protection in One Pass
Section 326: Where is the government list?
Frequency of Running OFAC List Against Customers
Timing for Checking OFAC on Loans
Checking Check Payees Against OFAC List
Loan Applications & OFAC
Blocked Parties, ACH, and OFAC
OFAC Help on Wire Transfers
Restriction of Card Use After Fraud
New Accounts: Handling an OFAC Hit
OFAC and Cashing Checks for Non-Customers
OFAC & PATRIOT Act Deadlines: What can wait?
OFAC & Check Clearing Requirements
OFAC & Joint Credit Cardholders
OFAC: Blocking vs. Rejection of Funds
OFAC Exemption?
OFAC Compliance Tips & Info
OFAC List v. Control List
OFAC Sanctions Matrix
ACH & OFAC
OFAC Is For Real
Selecting the Right OFAC Compliance Solution
What if an applicant is on the OFAC list?
Staying informed by email about OFAC changes?
Checking OFAC Each Time For Repeat Customers
OFAC Software Recommendations

USA PATRIOT ACT
Patriot Act & CIP - Minor Identification
Customers Signing the US Patriot Act Form
Government Agents/Employees Exempt from CIP?
Patriot act & Existing Customers
USA Patriot Act Signage
HOAs & the USA Patriot Act
Are You Hiring a Crook?
USA PATRIOT Act Confusion
Privacy and the USA PATRIOT Act
Accepting Accounts and Relationships
"Yes, That Check Will Clear," Violating the USAPA?
Explicitly Mentioning the PATRIOT Act on Lobby Notices
Ongoing Reviews and SAR Follow-Up
Copy of ID in Loan File OK?
Suspected terrorist: Beyond SAR, what steps to take?
Branch Robbery in Homeland Alert Times
Destroying 314(a) Search Requests
CIP and Business Customer TINs
CIP and Security Deposit Accounts
Two Forms of ID
Documentation of 314(a) Searches
Are Former Customers Considered "New" Customers?
OFAC & PATRIOT Act Deadlines: What can wait?
Retention of Loan Customer Driver's License Info
CIP Compliance Delayed
Adequate Advance Notice Under Section 326
USA PATRIOT Act Identification Requirements
USA PATRIOT Act, Safe Deposit Policy, and the Deputy
USA PATRIOT Act Account Opening Worksheet
Sharing Information Under the Patriot Act
Treasury Department Issues Proposed Regulation Implementing Section 312
120 Business Hours or Actual Hours
The USA Patriot Act and the Sleeper Provision
Overview of the USA PATRIOT Act
PATRIOT Act Product Packages Developed by BSI
Bank Needs in the Wake of 9/11


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