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Bank Bribery Act Bank Holding Company Act Bank Hours/Days Bank Protection Act Bankruptcy Bank Secrecy Act Bank Services Basel Capital Accord Beneficiary Bill Pay Biometrics BOD (Board of Directors) Bomb Threats Bonuses Branches Budget Business Accounts/Checks denotes Guru Question & Answer. Banking Related Court Cases -- See Court Cases Bank Bribery Act Accepting Gifts from Bank Customers Customer Gift Giving Accepting Gifts and the Bank Bribery Act Can You Be Bought? Bank Holding Company Act Reg O - Bancshares as Collateral Incentives and the Anti-tying Prohibitions Bank Holding Company Act Requiring Credit Life Insurance Anti-Tying Requirements Defined Consumer Protection Insurance Rules: What You Need to Know A Discount on a Loan for Getting Credit Life Insurance Bank Hours/Days Change in Branch Bank's Operating Hours Saturday - Right of Rescission Reg CC - Saturday Deposit of US Treasury Check Posting Holiday Closing Signs Number of Consecutive Business Days a FI Can Close Closing a Branch Early, Notice Requirements Return items for closed branches RESPA Disclosures on Saturday "We've Stepped Out -- Back in an Hour" Notice Requirement to Eliminate Saturday Banking Closing Branch to Repave Parking Lot Are Billing Dispute Days Calendar or Business Days? Guidance on Branch Operations Hours Requested Work Hours Changing Banking Hours Extended Hours For The Safe Deposit Area Full Service Banking On Sunday? Bank Protection Act One Person at the Branch Reason for the Bank Protection Act Height Markers Preparing Your Annual Security Program Report State Bank - Federal Law Enforcement New Emphasis on BPA by Examiners? Overflowing Safe Deposit Function Required Privacy Training Recommended Initial Training Monthly security meeting topics Facility Requirements -- Bank Protection Act Tracking Bait Money Bank Liability for Employee Parking & Safety Bait Money Bank Security Requirements Board of Directors Liability Definition of "Tamper-Resistant Lock" 10 Potentially Catastrophic Mistakes During Bank Robberies Alternatives to Bait Money/Bill Traps Teller Safety Issues Written Security Program Required Bank Protection Act Building Security Requirements Bank Protection Act Information Audit Program For The Bank Protection Act Bank Protection Act MORE ON TAMPER-RESISTANT LOCKS Question & Answer What In The World Is A Tamper-Resistant Lock? It's Working!�Or Is It?! Minimum Security Final Rules Bankruptcy Avoiding Bankruptcy Bank Employee Hiring Prohibited by Bankruptcy? Loan Collection of Customer Filing for Bankruptcy Denied Opening a Savings Account Loan Declined Due to Customer Filing Bankruptcy Bankruptcy - Re-scheduling Loan to Current Status Denying Credit Based on Past Bankruptcy Should This FCRA Notice be Sent to Bankrupts? Procedures for bankruptcies May We Deny a New Account? Maintaining Bank-Paid Insurance Premiums Disclosing Seller's Impending Bankruptcy to Buyer Reaffirmation in Chapter 7 Bankruptcy: Ten Questions Every Bankers Should Ask at a 341 Hearing Bankruptcy: Can we hot card a debit card? Loans, Collateral, & Bankruptcy Bankruptcy Discharged Debt: $0 on credit report? Advance To Debtor After Guarantor's Bankruptcy Upheld Bankruptcy & Collecting Late Fees Disqualifying Loans Based On Prior Bankruptcy Automatic Stay on Chapter 7 Advance To Debtor After Guarantor's Bankruptcy Upheld Predicting Bankruptcies Bank Secrecy Act Bank Secrecy Regulation Does this Add Up to a CTR? Insurance Companies and Anti-Money Laundering Phase I Exemptions Permanently Exempted? BSA Recordkeeping - Same Day Transactions Only? Inform Client of CTR Filing? Purchase of Monetary Instrument Under $3000 Gift Cards - Monetary Instruments? Unknown Depositor - CTR Filing Not Renewing Exemption - FinCEN Notification BSA Retention Policy & Loan Documents Government Lists for 314a Search Requirements Avoiding AML and OFAC Risks CTR Reporting - Never Exempt SAR Required on One Time Deposit or Withdrawal? SAR Filing on Suspicious Activity Under $5000 Exempting Once & Future Transactions Is Private Banking Risky? Effective Date of CIP Physical Address Rule SAR'd Customer Eligible for a Phase II Exemption? POA CIP Requirements When must a Casino file a Currency Transaction Report (CTRC)? CTR on Deposits into Personal & Business Accounts Close the Accounts to Be on the Safe Side? Commercial Loan Record Retention New SAR Form Still on Hold? CTR Completed in the Name Of? Casinos Compliance with BSA/AML legislation and the MLSA When should the Bank file a Currency Transaction Report (CTR)? CTR Reporting on Owners of Tax Exempt Organization When should the Bank file a Suspicious Activity Report (SAR)? CTR - 2 $9000 Checks Cashed at Different Branches CTR on Incoming Wires Aggregate the Transactions & File a CTR? BSA Board Training CTR on a Representative Payee Account A Business Cashing Customer's Checks OFAC - Credit Limit Increase LLC Account Opening BSA Exemption - Cash for Vault Replenishment BSA Violations - Civil Money Penalties Is Our BSA/AML Risk Assessment Adequate? CTR Filing on a Two Owner Business Safe Deposit Box & BSA Reporting Opening New Accounts Via Mail Wire Transfer - CTR Required? Filing a SAR on a One Owner Business PEP List Scanning For Your Customers Designating a Security Officer Interagency BSA (Bank Secrecy Act) Guidance BSA in Job Descriptions and Evaluations Verbal Request from the FBI CIP Info When Adding Account Owner Interagency BSA (Bank Secrecy Act) Guidance Reporting SARs to the Board of Directors MSB - Out of Country Wire Transfers CTR on a Family Trust CIP on Shared Loan CIP - Public or Government Account Signers CTR - Employees Cashing Payroll Checks CIP on Denied or Withdrawn Loan? Structuring - SAR Filing & Board Notification About the Bank Secrecy Act Enforcement Policy CTR Exemption List - Informing Customers Lost CTR To File or Not to File? PEPs and Potential Risk Amending an Exemption IRS Agent Blabs SAR Filing to Customer Non-Bank Financial Institution (NBFI) clients Phase II Exemption - Same Owners, Different TIN Furniture Store Acting as a MSB Proof of BSA/AML and Compliance Training Filing a SAR on Customer with a Fake SSN CTR Filing on Separate Deposits Setting Scoring Thresholds Based on Risk for Automated Customer Identification Program (CIP) Screening Software Tools USA PATRIOT Act Confusion CTR - Original Transaction or Combined Transaction CIP on Municipal Account Authorized Signers CIP Requirements- 4 Basic Criteria on all Signers? CTR on Night Deposits & In-person Deposits What Does MLRS Stand For? CIP - Church Youth Group Account Correcting an Unnecessarily Filed CTR How to Prepare for the New SAR CIP Proof in the File SAR Form Deadline Exempting Seasonal Businesses To File or Not to File, That is the Question Wire Transfers - OFAC Bank Name Check Treat Them as an MSB? Branch Isn't Following OFAC Procedures Close the Account or Continue Filing SARs? OFAC on Payees that Bank is Paying Pyramid Investment Scheme - File a SAR? Would Customer�s Regularity Warrant a SAR? CTR on Euros CTR - Savings Bond Purchased for Spouse Filing a CTR on a Cash Advance Is a Bank an MSB? Business Customer Exemption HR 323 & CTR Exemptions of Seasoned Customers Do We File a CTR When Multiple Checks are Cashed? Date Used in Second SAR Filing CTR - Customer Notification Filing a CTR - Check is Over a Year Old CIP on Authorized Signer Title Companies Required to file CTRs & SARs? CIP on Safe Deposit Box Signer CU Considered a Bank for Phase I Exemption? CTR Pamphlet "Reasonable Effort?" BSA: Report Change in Procedure to the Board? SAR = Something Ain't Right CTR Completion Guidance Exemptions and a Newly Acquired Bank Filling Out a CTR - Customer Query BSA Exemption List Removal CTR Filing - Deposit Made After Check Cashing Savings Withdrawal - CTR Required? OFAC Check on Purchaser & Payee CTR Exemption Extends to New Business? CTR Reporting Exemptions for Sole Proprietorships Different Accounts, Same Owner-CTR? New SAR Form CIP Form Record Retention File a SAR In Lieu of a CTR? CTR - DBA Account Monetary Instrument Sales Form and Log 15 Days to File a CTR - Calendar or Business Days? File a SAR In Lieu of a CTR? CTR Reporting � Exempt Organizations CIP - Indian Tribe Account Occupation "Retired"? Imaged Copies of ID HMDA, HELOCs and Monitoring Information CTR - Info From Both Account Holders Required? New SAR Form Announced Monitoring & Filing Supplemental SARS File a SAR After Filing a CTR Definition of Structuring Anonymous 'Remitter'? If Transactions are Over $3,000, Make a Copy? AML/BSA - Correspondent Bank Certification CIP on Purchased Loans CIP Notices on State Chartered CU's Website Filing CTRs on Joint Accounts Telling Customers the Bank is Filing a CTR $5000 counterfeit check - File a SAR? Statement of Purpose Copy of Drivers License in the Credit File OFAC Check on the Remitter BSA - Running Tickets During Currency Exchange 2 Deposits in 2 Accounts on the Same Day, CTR? BSA - Copying Driver's License for Each Loan PODs on the CTR? The Whats & Hows of MSBs Real Estate Loan Record Retention BSA Officer Reporting Directly to BOD Co-mingled Funds Shady Auto Loan Customer False Positives throwing off Compliance List Screening for OFAC Second ID for Existing Customers Legalities of Copying a Driver's License Training Requirements BSA Training for Board of Directors SAR Filing on Counterfeit Checks Safe Deposit Boxes - CTR Required? Aggregation for BSA Thresholds The USA PATRIOT Act & the Irate Customer Required Law Enforcement ID for an MIL CTR Information on Absent Account Owner Getting Around ID & SSN Requirments Deposit into Business & Personal Account, CTR Required? A Customer Wants a Copy of a CTR Customer Frequently Changes His Address Filing SARs & CTRs Online CTR on a Night Deposit OFAC on Beneficiaries of an Employee Benefit Plan Do We File a CTR on Another Bank? CIP & Loan Participations SAR - Our Bank Name Printed on Counterfeit Checks BSA Compliance on a Check Cashing Business Is There a Good Checklist of the Requirements for BSA Training? BSA Exemption: One ID Number for Multiple DBAs CIP & Brokered Deposits Assigning a High Risk Rating to a Repeat SAR Suspect SAR Filed on Insider, Who Can Sign It? Cashier's Check Subject to CTR Reporting? Scan the Signature Card, Keep the Original? What Constitutes a Monetary Instrument Exempt Customers of Acquired Bank Changing Signatures on Business Accounts CTR on a Long Time Customer Who Doesn't Have an ID AML - Non-customer Currency Exchange Deadline for Customer Due Diligence & Risk Rating Senior Level BSA Officer Exemption Revoked? Loan was Denied. Do We Still File a SAR? Completing/Maintaining a Monetary Instruments Log OFAC - Non-customer Check Cashing Rule/Reg Regarding 90 Day Review on Submitted SARs Refusing Suspicious Deposits SARS - When Does 30 Days Begin? How do we Justify our Perceived Risk Rating? Deposits into Exempt Account & Non-exempt Account Keeping Copies of Drivers Licenses with Loan Docs The Owner, the Employee and the CTR BSA & OFAC - Loans Purchased From Another FI CIP - Privately Held Co. Owned by Publicly Held Co Monetary Instrument Purchased by Employee Filing Additional SARs Is Beneficiary�s Street Address Required? Retention of Cashier's Check Log IOLTA - Beneficiary for CTR purposes? Payroll Cards - CIP on Business or Employee? I'm Cleaning up our CIP Files Former Customer Opens Account, No CIP? Keeping Photocopies of Sold Loans Prudent Banking Policy or Encouraging Structuring Consequences of AML Non-compliance CIP Audit Information Do We File a New Designation of Exemption? Should Banks Develop an Exempt Persons List? BHC Merging Banks -Refiling Current Exempt Persons MSB Risk Assessment on Business Loan Customers? BSA: Should We Be Doing This? Record Keeping of OFAC Screen Prints External Auditors Reviewing SARS Filed in 2005 Is this Structuring? CIP and IDs(PDF) Reporting MSB/High Risk Accounts to the Board CTR on Deposits in Personal & Partnership Accounts Are Additional Signers Included on the CTR? CIP on Business Loan Related Entities and BSA Licensure Verification for a NBFI/MSB List of Regs Requiring Training This SAR Has Been Sanitized......... Please Define: Domestic Correspondent Account CIP for 1031 Exchanges Checking "PUPID" Wires Against the OFAC List SAR Confidentiality SAR Filing Learn How to Write Reasonable Explanations Under BSA are Savings Bonds a Monetary Instrument? Bank of New York Pays to Avoid Criminal Charges Looking for BSA Risk Assessment Procedures Filling Out A CTR Safe SARs Service v. OFAC? Guru Chatter on BSA (pdf) CTR - BHC Tracking Deposits Across Bank Lines 314(b) Filer Downloadable Version of the CTR Exemption Form CTRs: Collecting Information Without the Customer BSA Record Keeping Requirements on Loans Accurately Filing a CTR on Uncooperative Customer CTRs: Documenting �Known� Customers Guru Says "Annual Reviews Required", Is this True? Do We the File CTR on both Minor and Parent? Exempt Customer Purchases New Business Does Depositing Third Party Checks Trigger BSA? Cashing Checks for a Fee, Register as an MSB? To ID or Not to ID Existing Customers CTR for a Customer with a Hyphenated Name Level of Account Monitoring to Comply w/BSA/AM Record Keeping on Paid Loans Purpose for Closed-End Home Equity Loan Reasons for Filing a SAR Section 326 and Grandfathered Account Owners Aggregation for Different Businesses, Same Owner How Does a Bank Determine If It Is In a HIFCA? Annual Reviews on Phase I Exempt Customer Does Bank File SAR for Scammed Customer? Is SAR Required on Crime With No Known Suspect? Patriot Act - Two Forms of ID to Open Account? CTR for Cash Back Transaction Guidelines on Exemption Reviews Sought Time Frame to File an SAR Do We File Two Designation of Exemption Forms? Check OFAC on Payee of Every Monetary Instrument Requiring IRS Subpoena on Information Not in SAR Phase 1 Exempt Business Going Thru Reorganization Automatically Exempting Customers w/ the Same TIN Guru Chatter on BSA (pdf) Obligations for Possible MSB Enhanced Due Diligence on a 34 Act Company MSB? Just an Ice Cream Parlor or an MSB? CIP Verification and the Four Big Items SAR on Customer Trying to "Game" Chexsystems? Section 326 Revisited 314(a) Record Retention Writing to Your Unregistered MSBs Negative Database Defined Small Banks Have New Wire Transfer Tool Action Audit Anti-Money Laundering Has Come A Long Way FinCEN Taps Bank for Penalty Documenting ATM Deposits Who is Listed on the CTR? Disclosing BSA Limits to Customers Collecting Data From MSB Accounts Aggregating Transactions for CTR Filings Wire to Exempt Government Agency SAR Investigations on 314(a) Matches BSA Training for Trust Area CTRs for Individual Depositing to Exempt Accounts CIP and Government Request Procedures Dropping a Customer from Exempt List Reviewing Phase I Exemptions Is Visiting a Business a BSA Requirement? Reporting a Beneficiary on a CTR Received Advice to Buy Multiple Cashier's Checks CTRs When Deposit is to Joint Account BSA Training Is For Everyone! I Changed My Mind Definition of "Tamper-Resistant Lock" Required Privacy Training Recommended Initial Training Due Diligence on MSB Customers $3,000 Log, Include the Fee? CTR Required for Check Cashing New Account Information Is armored transportation an MSB? Using Certified Mail for Filing CTRs BSA Exam Procedures for CIP Can We Disclose We Want To Exempt a BSA Documenting a BSA Exemption AML Policies, Procedures for an MSB Tribes Which Are CTR-Exempt Aggregating multiple branch cash activity CTR Instructions for a Minor's Account Exempting Correspondent Banks What are the new BSA Examination Procedures for Customer ID Programs? Possible Employee Structuring, SAR-able The Best Way to File a SAR or a CTR Concealing CTR Filing from the Customer BSA Requirement: Identifying Currency on Deposit Tickets Tricks to Identify High-Risk AML Accounts BSA Exemption Biennial Filing Question Exempt or SAR this Commercial Customer? Accepting Accounts and Relationships Filing a SAR for Payroll Fraud Exempting a Foreign Owned Company $3,000 Cash Sales Record Requirement Clarified: Cash Deposit / Debit Now Must Be Recorded If It is a Bad SSN, Do We File a SAR? BSA Training Requirements Guru Compilation: CIP (PDF) Guru Compilation: BSA (PDF) Guru Compilation: CTRs(PDF) Designation of Exempt Person BSA Exemption of Govt Entities Section 326 Takes Over: "The Devil Is In The Details" Risk Assessment Challenge: How Much Risk is "Reasonable and Practicable?" Special Terrorism Reporting Number Requiring an SSN is a Violation of Law, He Says Ongoing Reviews and SAR Follow-Up Check Cashiers CIP Requirements Cashier's Checks: Collecting Verification Info For Known Customers Developing A Successful Bank Secrecy Program: To Catch A Crook, Think Like One Back-filing CTR Instructions CIP Rules Define 'Customer' Important Exception to BSA Rule EXPIRES CTRs on Checks Cashed by Noncustomer Payee OTB Exemption for CTR Reporting Exchange and Deposit Totaling Over $10,000 Activity History Needed for CTR Exemptions Designation of Exempt Person Public Schools and CTR Exemptions Completing CTR Correctly on Check Cashing Completing a CTR for Aggregated Transactions Understanding Multiple Transactions and CTRs Multiple Currencies and New CTR Form 104 Dollar Threshold for Check Kiting SAR Format for CTR Form Submissions Full Disclosure of SAR Content Examples of Recognizing Suspicious Activities CTR for Weekend/Monday Deposits Deposit to Joint Account Triggering CTR Posting CIP Notices in Branches Section 326: Where is the government list? Aggregating Deposits of Chain Restaurants Timing Triggers for SARs CTR When Cashing Checks for Others BSA Enforcement: Expensive! Giving a Customer a Copy of a CTR CTR Required for Cashing Loan Proceeds Check? Smurfing Naming BSA Officer in Your Policy Getting a Copy of a CTR FinCEN Expands E-Filing System: BSA Reports Can Now Be Filed Over Secure Internet BSA Enforcement Retaining Records Regarding Forgeries 314(a) Search Request Questions Reportability of Cash Deposits into Two Accounts Important Exception to BSA Rule Extended BSA Exams: Lessons Learned by Experts BSA Compliance Matters Completing a CTR for Joint Account Deposits Internal Theft & Filing SARs New SAR Form and Software Suspicious Activity & Stop Payments CIP & SAR Filing Requirements CTR, Exempt Person Form, and Reportable Transactions Designing the BSA program to respond to risk Penalties for CIP Violations Tips for Ensuring an Effective Anti-Money Laundering Program Using a Facsimile SAR Are CTR Exemptions Mandatory? Fines for CIP Noncompliance Current CTR Form Expires? CTRs & "Multiple Transactions" CTR on an Estate Account Training To File SARs Filing SARs for Stopped Nigerian Scam OFAC: The New Compliance Hot Seat SAR Triggered by Invalid SSN? CTRs & Split Deposits Attorney-client Privilege & Filing a CTR Filing CTRs for Armored Car Currency Deliveries BSA Enforcement: Expensive! BSA Compliance Matters BSA Exemption Analysis Annual BSA Program Approval? E-filing your BSA reports (PACS) BSA, Exempted Business Accounts, and Change of Address BSA TIN Requirement & Religious Beliefs Required BSA Records What's the difference between KYC & CIP? BSA & Customs Form 4790 Non-Resident Signer With No SSN BSA & Recording The Amount of Currency Updated BSA Audit Procedures Updating BSA Policies To Accommodate Section 326 Rule Amending BSA Policy to Include Section 314(a) Requests Interstate Banking and CRA Notices CTR Exempt List: How should you handle an exempt customer that no longer makes frequent cash deposits? If payroll checks cashed for a business exceeds $10,000 in one day, does this need to be reported on a CTR? BSA/OFAC Lessons from Enforcement Actions TIN Requirements For Nonprofit Organizations Consequences of wrongfully granted BSA exemption BSA: Wire Transfer Area Software Is a loan application always required? CTR Reporting: Aggregating Deposits & Withdrawals Should we invest in a name matching software system? BSA: Should we file a late CTR if we discover an error on an old transaction? Cash Purchases, BSA, and Filing Requirements Under BSA, what is a sub-account holder? Account transactions, BSA, and Documentation Policies That Satisfy USA PATRIOT Act and BSA USA PATRIOT Act Identification Requirements Legal Documents In The BSA Exempt File BSA Brochures For Consumers BSA/ OFAC Lessons from Enforcement Actions Anti-Money Laundering Program The 120 Hour Rule Lending Disclosures at a Glance BSA/ OFAC Lessons from Enforcement Actions What a BSA Officer Should Be Doing Now ID Requirements For BSA Compliance Information Sharing: Should You Certify? AML Policy Requirement PATRIOT Act AML Rules Board Approval for BSA Policy Changes BSA Audit Requirements No Shortcuts for Updating BSA Policy Ineligible Businesses and BSA Exemptions Qualifications for a BSA Officer BSA Reporting Software BSA Brochure For Consumers Exemption Lists For Correspondent Banks Exemptions & CTR Filing Requirements FinCEN Advisories BSA and The Beatles -- A Training Exercise BSA - Practice Makes Perfect The ABCs of BSA BSA and The Beatles -- A Training Exercise BSA - Practice Makes Perfect We have to search for suspicious activity. Who says? Exempt Persons: Manually Monitoring Transactions Knowing What's Up with Know Your Customer FinCEN Issues more BSA Q&As Question & Answer New SAR COMPLIANCE NOTES - Keep Sight of the Goal KYC: Gone But Not Forgotten Question & Answer COMPLIANCE NOTES - Where's That CTR Warehouse? Question & Answer COMPLIANCE NOTES - Don't Overlook Private Banking Question & Answer What's Ahead In Compliance BSA, KYC: Staying Power Common Violations OCC Warnings On BSA Compliance EDITORIAL - The Unknown About Know Your Customer Question & Answer Question & Answer Question & Answer COMPLIANCE NOTES - Zap In That CTR Question & Answer COMPLIANCE NOTES - Leading Reasons for SARs Final Tier II Exemption Rules Released EDITORIAL - CTRs: Unnecessary Regulatory Burden? FinCEN's Acting Director CTRs What Will Phase II Exemptions Really Save? Question & Answer Question & Answer Don't Let SAR Reporting Backfire COMPLIANCE NOTES - No Exemptions for SARs Filing SARs How Safe Is The Harbor? More On the New Compliance World Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer Question & Answer New Itinerary Proposed Changes to the Travel Rule COMPLIANCE NOTES - $0 CTRs: Status Update COMPLIANCE NOTES - SARs: Common Violations KYC COMPLIANCE NOTES - Annual Cash Aggregation?! FinCEN Proposes New Exemption Rules Question & Answer Know Your Customer Soon - Somehow COMPLIANCE NOTES - Customer Service v. Suspicious Activity