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?
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?
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 ..."
Does due diligence require asking 'Does this revenue derive from marijuana related activity?'
Do Patriot Act Notices and UBO notices have to be on the bank website? We do not open accounts online at this time.
Can copies of SARs be maintained in electronic format?
What is a legal entity?
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?
Are there any countries that do not issue taxpayer identification numbers?
How do I start preparing for the new Beneficial Ownership/CDD rules?