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November 19
How to Conduct an Interrogation
Dana Turner

November 19
Blocking Internet Gambling -- Are You Ready?
John Burnett

November 20
Understanding Letters of Credit
Adam LaBoda

December 2
Auditing for the "Orphan" Compliance Regulations
Patricia Cashman

December 8
Robbery Suppression & Apprehension -- The SAFECATCH Strategy
Dana Turner

December 10
RESPA - Completing the New Good Faith Estimate
Mary Beth Guard and
Jack Holzknecht

December 16
RDC Risk Management and FFIEC Compliance: It is harder than you think!
Paul Carrubba and
Dan Fisher

December 18
RESPA - Completing the New HUD-1/1A
Mary Beth Guard and
Jack Holzknecht



Topic Options
#1283024 - 11/06/09 04:53 PM Regulation GG and FedWire
Dr. Zoos Online
Diamond Poster

Registered: 01/29/04
Posts: 1347
Loc: Not Where I Should Be
Has anyone received assurances from FedWire that they are blocking wires related to illegal Internet gambling? If so, when/how was the communique transmitted? Thanks!
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"Our lives tick by like pendulum swings, poor little things, puppets on strings."

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#1283174 - 11/07/09 04:00 PM Re: Regulation GG and FedWire [Re: Dr. Zoos]
Ken_Pegasus Offline
Power Poster

Registered: 08/30/01
Posts: 9729
Loc: Another trip around the sun
It's literally an impossibility that any wire system could identify and block wires in process that are derived from gambling, legal or otherwise. Only the card system has that capability and it is dependent on the proper use of codes.

Regulation GG only contemplates the possibility that the card system will offer assurances.
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Try? There is "do" and "do not," there is no "try." Yoda

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#1283635 - 11/09/09 03:00 PM Re: Regulation GG and FedWire [Re: Ken_Pegasus]
HappyGilmore Online
Compliance is my life

Registered: 06/11/04
Posts: 13511
Loc: Who'dat nation
FRB will not be doing this, any more than they scan wires for OFAC compliance...
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Occams Razor - it's not just for shaving!


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#1283711 - 11/09/09 03:44 PM Re: Regulation GG and FedWire [Re: HappyGilmore]
beth@pcb Offline
New Poster

Registered: 08/30/06
Posts: 8
Loc: georgia
The sample policy I looked at on BOL says "the bank is not required to block ACH, wire, or check payments..."
Is this true? Are we only supposed to be concerned with debit/credit card transactions? What about the "designated payment systems" mentioned in the reg?

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#1284148 - 11/10/09 10:02 AM Re: Regulation GG and FedWire [Re: beth@pcb]
John Burnett Online

Compliance is my life

Registered: 10/27/00
Posts: 18557
Loc: Cape Cod
As a beneficiary's bank under a wire system such as FedWire or SWIFT you are expected to have a program in place that is reasonably designed to block or otherwise prevent your customer from receiving a wire transfer that is a restricted transaction.

There is no way for you, as the beneficiary's bank, to know the purpose of an incoming wire. Therefore your reasonably designed program has to focus on preventing a commercial customer from accessing incoming wire transfers. The procedures for such a program would ordinarily consist of a series of customer due diligence vetting questions used to determine whether a prospective commercial customer will be engaged in the business of Internet gambling, and, if yes (and if the bank wants to pursue the account relationship further), whether that Internet gambling business is legal (licensed). Put more simply, your procedure would be designed to prevent the bank from accepting as a customer a commercial enterprise that might operate an illegal Internet gambling business.

I'll be re-presenting my "Blocking Internet Gambling -- Are You Ready?" webinar on November 19. You should see a link to the program information to the left of these Threads.
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"I guess I should warn you, if I turn out to be particularly clear, you've probably misunderstood what I've said." -- Alan Greenspan

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