DO YOU KNOW. . .
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When you have classified all your accounts, you may not have any that are "high risk." |
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You should have a list of your Non Resident Alien customers for monitoring. |
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There is no list of Politically Exposed Persons, but you should identify them. One of the best ways to identify a PEP is to ask the customer. |
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The board is not required to have copies of SARs. They can receive a summary report, or even delegate a committee for SAR reviews. |
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Continuing suspicious activity triggers subsequent SARs, but filing within each 90 day period will be sufficient reporting. |
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A vendor you outsourced work to is an "insider" for SAR reporting. |
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Reporting suspected tax evasion on a SAR is a voluntary report on the part of the bank. |
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There is no requirement that a check casher charge a fee to be an MSB. |
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"Closed" stored value cards may be used in limited places, as in one particular store or chain of stores. These pose fewer BSA risks than cards accepted almost universally such as where MasterCard or Visa cards are accepted. |
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You will want to monitor MSB customer compliance with all applicable state and federal registration and licensure requirements. |
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If you have an MSB customer, as a part of your review you may request their CTRs. |
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