We have many customers that deposit a lot of cash. How do we determine if the amount is reasonable?
I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?
Our bank is basically taking the position that we will not provide services to marijuana related businesses. We need to add this verbiage to our policy but I am unsure of the best approach. My thoughts are..
*We will not provide banking services to marijuana related businesses. (straight forward)
*We will not provide banking services to entities or individuals who activity is not considered legal at the state and federal level. (not segregating a specific business)
*After conducting a risk assessment we have determined that we will not provide banking services to marijuana related businesses.
Any insight you may have is appreciated.
I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
During new hire training the question was asked, If a transgender person conducted a transaction which required a CTR, what should be marked for the gender? The thought process was, if the customer identifies with the gender not marked on his or her state ID or driver's license, which do we select? My thought is to choose unknown, even though we never use that option otherwise.
Is it possible to money launder in the hotel industry?
We have a corporate customer with three accounts. One of the accounts includes a "DBA" business name that the corporation also uses, but all the accounts show the same location and EIN. When we file CTRs on the two accounts that don't include the DBA business name, should we be including the DBA on the CTR?
Is a social security number required on a CTR for the person conducting the transaction. For example if the person refuses to provide SSN, to cash an $11,000 check, do you refuse to cash?
If a SAR is filed, is it mandatory that any client accounts must be closed?
Is the Currency Transaction Report 104 a part of the Anti Money Laundering documents that needs to be signed by an Attorney?