Does anyone have thoughts on what area of the bank should be responsible for Reg. GG (Unlawful Internet Gambling)? I feel several areas of the bank should be involved in the developement of the new Policies and Procedures for Reg. DD BUT what area of the bank should have the ultimate responsibility? Internet Banking Dept., ACH Dept.? BSA Dept.?

In a recently attended seminar it was stated BSA would have a "tiny part" with Reg. GG. He stated we "might" need to change our CIP Policies if we required diff. documentation at acct. openeing for Commercial Accts. and that we would have to do SARS if/when we suspected someone of Unlawful Internet Gambling. Any thoughts on this?

Thanks

IMHO...agree with the statement that BSA would have a tiny part with Reg GG, but if your institution is sooooo departmentalized that you are having difficulty placing responsibility to any one department, then I would recommend giving it the ability to span over several areas Like BSA does. So that might mean assigning it to BSA.

Our Compliance person will have overall responsibility. (She also does the rest of the "alphabet soup" regs)

We work very well together - so I'm sure I'll have a thumbprint in the policy

FYI, we have an Officer who is responsible for our Internet Banking Operations as well as our ACH area.

^^^^^That is where I would put it.

I was hoping you would agree with me on that. Thanks soooo much for the replys. I would still like to hear from others if there are any diff. opinions.

We're a small bank, and don't have a "Compliance Officer" position; those responsibilities are born by senior officers in different areas of the bank.

So for something like Reg GG, our Operations Committee will oversee the Regulation. Officers from areas such as New Accounts, Bankcard, ACH etc. sit on the committee. Generally, the officer whose area is impacted the most by the Regulation will draft a policy, but it gets circulated to the other Officers for input and then to the rest of the Operations committee for review. We have an outside Operations Auditor that comes in and reviews our procedures for compliance issues.

Lucky me- I oversee our Bankcard Dept., and got the task of writing the Reg GG policy because my Department has to block transactions. But I worked very closely with the senior Officer that oversees our New Accounts because we have to have procedures in place for opening commercial accounts. Lastly, our Security Officer sits on the Operations committee, and she is responsible for any relevant SAR reporting.