Are we required to get an updated photo ID on an existing customer when we open a new account relationship with them (i.e. a loan, DDA, savings, etc)?
Can the bank legally close or freeze an account that is suspected of money laundering and hold the funds in a general ledger account pending investigation?
We think we heard Brian Crow say, at TopGun Mar. 2020), that if we acquire a loan from a non-covered institution, that did not collect Beneficial Ownership certification from a legal entity borrower, we now must do so. I'm looking for citation of that requirement in Regs or guidance etc. We're about to do exactly that scenario.
Can you use "student" for an occupation on a CTR?
On a CTR form, if the transaction is being completed by the owner of an entity do we check Person conducting transaction on own behalf in Part1,
Person Involved in Transaction?
Are banks required to risk rate a CD at account opening?
How would I complete a CTR for an estate? The Trust Dept. opened deceased customer's safe deposit box and found $75,000 in cash. Funds were then
deposited into a trust fund. I know the trust employee will be the transactor but how do we handle the "on behalf of"? Do we just put customer's name even though he is deceased? There's no where to put "The Estate of ..."
We are a de novo bank and our BSA officer mentioned that it was "recommended" by FDIC regulators that banks need to check their
correspondent banks on OFAC anytime they send or receive a wire from them. To me this seems pointless and quite excessive. We send/receive wires
through PCBB and I can't see us needing to check OFAC lists for their name daily. Is this really necessary?
XYZ, LLC was opened with a certification of two individual signers owning 10% and 16% of the company. However XYZ’s company agreement stated that another LLC (ABC, LLC) owned 90% and one individual (one of the signers) owned 10% interest of the company. The ABC, LLC was not indicated on the certification.
Based on the XYZ’s company agreement, do we need to request beneficiary ownership information on the ABC owners?
The NCUA has a regulation that will not allow a federal Credit Union to close out a member's relationship without being approved by the NCUA Board. However, the FFIEC manual allows for an institution to close out a member due to multiple SARs. Does the FFIEC Regulation supersede the NCUA regulation that requires approval before closing out a relationship?