Latest Compliance - BSA Topics

Internet Gambling Site Exemption UIGEA

09/19/2021

I have a customer that appears to be processing personal transactions through his business account with FanDuel internet gambling site. FanDuel operates under a specific exemption written into the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA) that allows for fantasy sports contests. Am I correct in thinking that the use of FanDuel is not a violation of Reg GG? Also, is conducting personal transactions through a business account SARable?

314a Scans of Wire Activity (OFAC)

09/12/2021

Regarding OFAC compliance, should my 314a scans of wire activity include both domestic and international wires or just foreign wires sent or received?

Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Currency Transaction Report Filed by Mistake

07/04/2021

Can you tell me where to find guidance on, or when to actually do, when a Currency Transaction Report was filed by mistake?

Add Cash Back Amount to Reportable CTR?

06/06/2021

I have a reportable CTR to file. It was created during banking hours. I found out that our client did a POS and got cash back. The POS transaction happened after banking hours. Do we need to add the cash back amount to the reportable CTR?

Beneficial Ownership information on Loan Guarantor

02/07/2021

Is it a requirement to gather Beneficial Ownership information on loan guarantors?

Withdrawals Over $10K from ATM-CTR?

12/20/2020

If a client withdrawals over $10K from an ATM machine over the weekend, Saturday and Sunday are we required to file a CTR on our client?

Risk Rating on Customer Opening New Saving Acct?

11/15/2020

Should we complete a risk rating on a customer opening a new saving account, as an example, or how are the accounts selected that this is completed on, i.e. based on what criteria?

Monetary Instruments Log for Credit Union

08/09/2020

I am trying to create a monetary instruments log for our credit union. I have not been able to find a list of the required information needed on the log. Where can I find that information?

Back-office Document Imaging

06/21/2020

What types of back-office documents do banks image and store electronically?