Vendor Guru Q&A - Compliance

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Latest Compliance - AML/BSA Topics

Revenue Derive from Marijuana Related Activity?

12/16/2018

Does due diligence require asking 'Does this revenue derive from marijuana related activity?'

Disclose Subject Appeared on FinCEN's 314a List?

11/04/2018

Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?

CBD Business Legal at Federal Level? SAR?

10/21/2018

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?

LEIs or not?

07/22/2018

What is an LEI? Do we have to use it to establish beneficial ownership certification?

Who Signs Beneficial Ownership Certification Form

07/08/2018

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?

Release Copy of Check for CTR that was Filed?

07/08/2018

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.

SAR for Municipalities (Medical Marijuana)

04/01/2018

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?

Certificate of Beneficial Ownership Form

04/01/2018

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.

New Beneficial Owners Certification Form

02/25/2018

Should a new Beneficial Owners Certification form be completed every time a new account is opened if there have been no changes in the beneficial ownership of the legal entity? Can the certification form currently on file be copied, re-signed and re-dated rather than complete a whole new form in those instances?

Where does a nonresident alien live?

02/11/2018

What address should we get on the W-8BEN?

IRS levies and Treasury’s Garnishment Rule

01/13/2019

Are IRS levies covered by the Treasury Department’s Garnishment Rule?

Protected accounts under the Garnishment Rule

01/13/2019

Which customer accounts are covered by the Garnishment Rule?

Cash Deposit At Teller Counter-CTR?

01/13/2019

A customer presents a cash deposit at the teller counter in the amount of $10,000. The teller counts the deposit and discovers it to be $100 over. The customer is made aware and requests the teller to give back the $100. Does this qualify for a CTR since it was handled by the teller while counting the large cash deposit or is it a simple mistake by the customer? We are also considering a SAR for possible structuring by the customer.

Trust that is Not Specified-Revocable

01/13/2019

If a trust account is opened and is not specified to be revocable or irrevocable, does that automatically make it revocable?

CD Interest Paid Monthly Change to Compound

01/13/2019

If a customer with a 4 year CD with interest paid monthly, after 6 months, decides to have it compound annually, what would be the next date for interest to be paid? The opening date was 1-1-2016.

Latest Compliance - AML/BSA Topics

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