FFIEC Exam manual changes add a word practice. What is that?
Some taverns/bars are involved in "Sporting Pools" aka: Football Pools, Office Pools, Super Bowl Pools, etc.
Does FinCEN encourage SARs to be reported for a business involved in such activity? Gambling is not legal in my area.
Is there a way to know if any SARs submitted to FinCEN by my institution were among those leaked in the recent data breach?
A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed.
My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?
Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?
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?