One more question...my company is a third party recordkeeper of retirement plans. When a participant withdraws their money, and then changes their mind within the 60 days law allows them, and the money is wired back to us, does this show up as a laudering issue? I have the Fed and State in the office this week. Fun, fun, fun.

Burnett, RlCarey, Gilmore, where are you? (Said in a Shaggy-like scream for Scooby)

I need help!

I would think that in your account type AML risk assessment, these account would be rated as very low risk from an AML perspective. Laundering money through qualified retirement accounts would be pretty tough to do in any real quantity. I don't think it is much of a concern and if you have an examiner grilling you on it.....oh boy...............

This type of thing is more of a risk when investments like annuities are purchased and quickly cashed out. A long term investment is a pretty slow payback for a laundering scheme. I would view this as very low risk for laundering or any type of fraud.

Absent any other unusual behavior by the customer, I would stick by that determination.

Thanks, folks. They relented today. Perhaps they are just trying to see how competent we are (or are not)