Looking for some input on credit card cash advances and BSA. We have mad a decision to begin to do cash advances and I'm tryimg to think of BSA issues if we allow our customers to get up to $5,000 and non-customers to get $3,000. The thing is though - they could potenially go to several branches in one day - do we need to capture in for CTR? Do we need to maintain info for $3,000 log? I guess we would need to retrieve info for 314a request also? What are some of you doing w/ cash advance record keeping? What else do I need to think about?

Don't forget to consider OFAC

You may want to talk with your service providor as they may electronically have the information for 314a review.

I would like to know how a cash advance differs from an ATM withdrawal by a noncustomer as they are similar and most of our cash advances take place whan our ATM network is down. We haven't been doing anything with advances for BSA purposes

If someone could potentially go to several branches in one business day and walk out with over $10,000 total that would be a CTR reportable transaction if you "have knowledge" that the cash advances were done by or behalf of the same person. If you don't have a monitoring system in place to catch that, you won't "have knowledge" and you won't be able to report. I think your trouble there would be that that may be perceived as a weakness in your BSA program to allow some transactions to slip through the cracks.

314(a) would apply. We have a log at each branch to record non-customer cash advances. That is sent monthly to our BSA Officer, who enters the info into Excel, and then that Excel file is searched every two weeks when the 314(a) list comes out.

Is it a requirement to offer cash advances to non clients. Someone told me that VISA tells its customers they can go to any bank and do a cash advance. Do we need to check OFAC on these people?