01/19/2020
A customer cashes a large check that results in a reportable CTR. My question is that the funds from the check are for Christmas bonuses for the
customer's employees. I have the customer as the conductor, but who will be the beneficiary? Can we list the business as the beneficiary?
12/01/2019
We have learned that if a customer has an address outside of the U.S. they cannot use the bill pay feature of our internet banking program. Once their address is changed to a U.S. address they do have access to bill pay. Is this a requirement due to a U.S. banking regulation regarding persons with international addresses and online payments? Or is this simply a voluntary security feature of our online banking vendor?
10/13/2019
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 ..."
12/16/2018
Does due diligence require asking 'Does this revenue derive from marijuana related activity?'
09/09/2018
Do Patriot Act Notices and UBO notices have to be on the bank website? We do not open accounts online at this time.
06/24/2018
Can copies of SARs be maintained in electronic format?
04/01/2018
What is a legal entity?
03/04/2018
Our BSA officer insists when a customer deposits or withdrawals over $5,000 in cash, we have to ask what the cash is being used for. Is there regulation to support this? I understand CDD, but isn't this taking it too far? Is it our job to be nosey?
01/21/2018
Are there any countries that do not issue taxpayer identification numbers?
10/29/2017
How do I start preparing for the new Beneficial Ownership/CDD rules?
