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?
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.
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?
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.
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?
02/11/2018
What address should we get on the W-8BEN?
02/04/2018
Do we have to bank nonresident aliens?
02/04/2018
Can a financial institution run Chexsystems on a business? Or do we run Chexsystems on all beneficial owners and signers upon written consent?
01/28/2018
Can a nonresident alien have a social security number?
12/03/2017
I have read several scenarios on currency in a deceased person's safe deposit box. We have one that I am not sure will meet the definition of "transaction" Case is single renter deceased, box drilled upon non-payment of rent. $18,000 in currency was in the box, that along with other items was verified under dual control and put into safe keeping. Later, staff started tracking down the estate or likely survivor. We found his spouse, and she had no idea he had the box. Upon proper documentation of her right to have box contents, she was given the currency, and no one at the branch considered that a CTR might be required. Since the dollar amount was never placed in a bank account of any kind, there was no transaction that the CTR software could see, so it did not appear there, or in BSA AML monitoring software. It is well past time to file. Do we need to start a back-filing request to FinCEN?