The FDIC, OCC, and the Federal Reserve recently published updates of their Bank Secrecy Act exam procedures, each incorporating changes made by the USA PATRIOT Act.
I have just been nominated compliance officer of a thrift at which I am a new employee (this is my 3rd week). I have 15 years previous banking experience in almost every department but never in compliance. Where should I start?
Auditing Your AML Program
According to Stevenson Munro, the most common question he gets at OFAC is what to do when an institution finds a good hit on the OFAC list.
It isn't just filing CTRs anymore. Bank Secrecy used to be primarily about paperwork - paper that got stored somewhere in a warehouse rumored to be in Detroit.
What fines can be incurred if we are not fully compliant with CIP?
This is in regards to the Bank Secrecy Act, Administrative Ruling 885, CTR Filing requirements for Armored Car Transports of Currency. My question is What if a Armored Car Service collects currency from our Correspondent Bank for our customer, and the Armored Car Service delivers the currency directly to ATM machines. The currency is never received by us or by our customer. Does a CTR have to be filed?
by Ken Proctor, Director of Risk Management, Brintech, Inc.
I am looking for information on the Bank Protection Act. Can you point me in the right direction?
I am in the process of my annual review of CTR exempt customers under the Bank Secrecy Act. I have come across a customer that is no longer making "frequent" cash deposits. They only made 5 in the last year. My question is two part: Do I take them off of exempt status since they no longer meet the definition? If the answer is yes (I think it is), do I revoke the exemption by filing with the Treasury Department or just begin filing CTR's on all cash transactions going forward?