Most Popular Compliance Content
Duplicate ATM Withdrawals
05/09/2021
Recently my bank began to duplicate ATM withdrawals for some customers. For one customer alone it could amount to several thousand dollars. This went on for months before the customer and the bank discovered the problem. At that time the customer sent an email to our helpline asking for assistance and claiming that she had not made the duplicate withdrawals herself. I’m inclined to let her go through the process of trying to prove that she did not make these withdrawals herself. She was in Mexico and I believe it will be very hard to get a Mexican bank to help her. Unfortunately our customer assistance sent her a reply stating that the bank had a known issue creating duplicates for ATM withdrawals. Otherwise how can she prove it? Are we in any danger if she does take legal action? Since she is in Mexico I had the customer service write her back and tell her she needs to go to her local bank and take care of it herself. That has been our standard reply since for similar claims. If she takes legal action what are the odds that we would lose and have to pay her back all that money? Can we simply delete the email we sent to her saying we had a known issue with duplicates on ATM withdrawals? Then she’d have no proof whatsoever. Please advise.
Duplicate ATM Withdrawals
05/09/2021
Recently my bank began to duplicate ATM withdrawals for some customers. For one customer alone it could amount to several thousand dollars. This went on for months before the customer and the bank discovered the problem. At that time the customer sent an email to our helpline asking for assistance and claiming that she had not made the duplicate withdrawals herself. I’m inclined to let her go through the process of trying to prove that she did not make these withdrawals herself. She was in Mexico and I believe it will be very hard to get a Mexican bank to help her. Unfortunately our customer assistance sent her a reply stating that the bank had a known issue creating duplicates for ATM withdrawals. Otherwise how can she prove it? Are we in any danger if she does take legal action? Since she is in Mexico I had the customer service write her back and tell her she needs to go to her local bank and take care of it herself. That has been our standard reply since for similar claims. If she takes legal action what are the odds that we would lose and have to pay her back all that money? Can we simply delete the email we sent to her saying we had a known issue with duplicates on ATM withdrawals? Then she’d have no proof whatsoever. Please advise.
Documents for Opening Acct for Non-resident Alien
05/09/2021
What documents do we need to open accounts to be in compliance for non-resident aliens other than the regular documents (CIP etc)?
USA Patriot Act- CIP Notices
05/09/2021
We provide services non-account holders, as well as account holders. Our platforms require the creation of customer "folders" for all teller transactions. This means we capture CIP elements to create non-account holder folders to process those transactions. As the USA PATRIOT Act requires the capturing of CIP elements for account opening only (as far as I understand), are we also required to post customer CIP notices at the teller stations as well for non-account holders? Logic would dictate that the answer is yes, because the same CIP information is being collected for both groups, and we practice our KYC and AML principles for both. (Non-account holders or "consumers" can launder money or finance terrorism just as easily, or more easily, as an account holder.) However, the PATRIOT Act only requires the notices for account opening activities/locations. Technicality, I'm sure. But what is the right thing to do?
What is “Abusive,” technically?
05/02/2021
In terms of UDAAP, what makes something “Abusive”?
