09/29/2024
I have read through several articles on private ATM owners and the enhanced due diligence on these; however, none seem to call out private ATM owners that do not have access to fill the ATM. Would these customers have the same expectations? Would it be necessary to tag these customers, obtain contracts/agreements and do yearly reviews of activity?
09/01/2024
We have a commercial customer that cashes checks, but they are not registered as an MSB because they have a policy to not cash checks for one person over $1000 in one day. We found one instance of checks cashed over $1,000 for one person. Are we required to have the customer register as an MSB, or can we verify their check cashing policy and continue to monitor the
account for any further instances?
05/05/2024
If our institution banks an entity that is registered as an MSB but, the entity does not hold their MSB account at our institution, are we still required to complete a full MSB high risk review or even have them marked as an MSB?
05/05/2024
Should you log a cash advance to the BSA log after the cash advance was used to purchase a Cashiers Check? No money was exchanged.
04/14/2024
We have a client who deposited a reportable cash transaction into he and his wife's trust account. We know we have to file the CTR for both wife and husband (joint account) but do we have to include the trust as a beneficiary?
01/28/2024
We have a business customer whose deposit runners are refusing to provide their information for us to collect as conductors of cash transactions. These are typically smaller transactions, but we require a conductors information on all cash transactions over $1,000 for aggregation reporting purposes. They previously banked at a larger regional bank which did not require these runners to provide identifying information. Are we OK to make an exception for this business client unless it is a CTR reportable transaction?
01/21/2024
I have a CTR question I have yet to see posted anywhere. Any cash
transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?
11/12/2023
We have a customer that is a US citizen and resides in the US. He is employed by a company in Australia and the company is doing business in Arkansas, It is a lithium battery business. The people associated with it are Australian citizens, with no U.S. tax IDs. What do we need to be in compliance with BSA if we do open accounts for them?
09/03/2023
If we have a revocable living trust, and the Grantor and Trustee are different, would we CIP both the Trustee and
Grantor, or just the Trustee?
07/23/2023
We have a non-banking client who received several checks from his deceased grandmother (our client) which total over $10K. He is traveling from KS to Fla to cash these checks. Our problem is that he doesn't have a Social Security Number. Can or should we cash the checks and create a CTR, or refuse him? He does have a DL. He lives off the grid....we will file a SAR for sure.