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#411892 - 08/23/05 01:46 PM NGO's
rwhlpn Offline
Junior Member
Joined: Aug 2005
Posts: 38
With the new rules coming into play, I'm sure alot of your banks have charitable foundations. How are you planning on dealing with the new rules for NGO's?

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BSA/AML/CIP/OFAC Forum
#411893 - 08/23/05 01:58 PM Re: NGO's
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
We already cover the items listed on pages 162-163 in our Customer Due Diligence for these types of accounts. Further, they are treated as a special group within our AML monitoring software..

Of course, only our next exam will tell whether that's good enough....

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#411894 - 08/23/05 02:04 PM Re: NGO's
rwhlpn Offline
Junior Member
Joined: Aug 2005
Posts: 38
Sorry, I guess I wasn't clear. My bank has it's own Foundation that gives a $1,000,000 to charities that would be considered a NGO. These NGO's do not have accounts at this bank. Although a grant application may say the request the funds for one thing, it could be used for another.

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#411895 - 08/23/05 02:09 PM Re: NGO's
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
Sorry, you're right, I wasn't looking at it from that perspective. Out of curiosity, does your grant application cover the information you'd expect to collect if the applicant were a customer? Also, do you have the applicant set up an account at the bank, and disburse the funds into the account?

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#411896 - 08/23/05 02:16 PM Re: NGO's
rwhlpn Offline
Junior Member
Joined: Aug 2005
Posts: 38
The grant application doesn't come close to the old CIP requirements, let alone the new stuff on NGO's. The funds get disbursed by check at a social gathering to maximize publicity. We receive over 500 apps and give $$$ to 50-75. I'm struggling with the due diligence.

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#411897 - 08/23/05 03:11 PM Re: NGO's
15jwolander Offline
100 Club
Joined: Jan 2004
Posts: 208
PA
Can someone tell me what new rules you are discussing and where I can locate them? Thanks

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#411898 - 08/23/05 03:34 PM Re: NGO's
Hrothgar Geiger Offline
10K Club
Hrothgar Geiger
Joined: Jun 2005
Posts: 10,395
Jersey Shore
Pages 162 and 163 of the new BSA/AML Examination Manual

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