I am seeking some advise on BSA regulations around aggregation of secondary account holder. Is it a requirement by FinCEN to aggregate transactions based on secondary relationship between accounts and file a CTR?
Example: Joint account relationship
Account (A) - Chris (P) / Joe (S)
Account (B) - Joe (P) / Brian(S)
Chris as a conductor makes 6K Deposit into Act A at Branch X
Later, Joe as a conductor makes 5K Deposit into Act B at Branch Y
should a CTR be filed considering Joe has secondary relationship with Chris in Account A and ultimately benefits from the deposit made?
Can a trust be the sole owner of a business like a sole proprietor?
Does due diligence require asking 'Does this revenue derive from marijuana related activity?'
Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?
Is a canabidiol (CBD) business legal at the Federal level. I understand it is legal in all 50 states but unsure about the Federal level. Would it be treated the same as a marijuana related business where a continuing SAR would be required?
What is an LEI? Do we have to use it to establish beneficial ownership certification?
Who signs the Beneficial Ownership Certification form where it
states " I,____, hereby certify, to the best of my knowledge, that the
information provided above is complete and correct ? The bank employee or the
Beneficial Owner who is opening the account?
Is it proper to release a copy of a check for a CTR that was filed? The agent want to know the source of funds.
We currently bank municipalities/public funds who are considering allowing medical marijuana business in their community. Sounds like it will cost about $5,000 per license upwards of 25-50 applications allowed. Do we need to report the activity in a SAR that the municipality is accepting applications?
123 LLC is owned by 2 individuals both at 33.33% and ABC, LLC which owns 33.34%. The natural individuals of ABC, LLC are John and Jane Doe. Would John and Jane Doe, in fact, be 16.67% owners of 123, LLC? This question is in regard's to the Certificate of Beneficial Ownership form.