The bank received a phone call from a non-customer who stated that their business email had been compromised as a staff member of theirs received what appeared to be a wire request from the CEO, however, it was discovered that the CEO did not send the request. The request listed our customer and account number as the beneficiary of the wire. Would this be considered an attempt by an unknown subject or because we did not specifically get the wire or the wire request, just a call from a non-customer and an email forwarded from them, would this not be considered reportable?
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.
When filing a CTR on a business, and only one account signer made the deposit, is it required to get the information on the other signers that were not present to file the CTR?
Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?
The FFIEC Exam Manual refers to Politically Exposed Persons, as a "senior foreign political figure". We have Examiners here, who also have stated that they are only foreign political figures (and their families, close friends, & associates, etc...). But, we had a State of Arkansas House of Representative come up as a "hit" on the Enhanced Politically Exposed Persons (PEP) list when we ran them through the OFAC section of Chexsystems. So, I am just looking for some clarification or guidance on this.
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?
Can we remove a joint owner of a DDA account if they did not provide CIP information within a reasonable period of time? We have the primary account holder's information so we don't want to close it. However the joint party never returned with their information, even after notices were sent.
What is an LEI? Do we have to use it to establish beneficial ownership certification?
Can we open a low profit LLC?
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.