Vendor Guru Q&A - Compliance

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Latest Compliance - BSA Topics

Revenue Derive from Marijuana Related Activity?

12/16/2018

Does due diligence require asking 'Does this revenue derive from marijuana related activity?'

Patriot Act Notices/UBO Notices on Bank Website?

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.

SAR Document Management

06/24/2018

Can copies of SARs be maintained in electronic format?

Are IOLTAs in for beneficial ownership?

04/01/2018

What is a legal entity?

Asking What Cash is Being Used For (Over $5,000)

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?

Does every country issue a taxpayer identification number to a resident?

01/21/2018

Are there any countries that do not issue taxpayer identification numbers?

Getting ready for Beneficial Ownership

10/29/2017

How do I start preparing for the new Beneficial Ownership/CDD rules?

Methodology of BSA Audit Quality Control

10/01/2017

I need to find out the methodology of BSA audit quality control. Is there a check list to ensure my audit firm is doing a good audit job? (basically evaluate the quality of audit, including scope, procedures and work papers).

CDD Regs: Verify Signer & CIP? (Participant Loans)

09/24/2017

With the new CDD Regulations, will we need to verify signers and CIP on participant loans? Also - Is there a specific way to verify the information for CDD with the shareholders of a company?

Our accounts play by our rules

06/11/2017

The customer, who was born and raised just down the street from our bank, refuses to provide his Social Security number. What should we do?

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Expiring Individual Taxpayer Identification Numbers (ITINs)

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IRS levies and Treasury’s Garnishment Rule

01/13/2019

Are IRS levies covered by the Treasury Department’s Garnishment Rule?

Protected accounts under the Garnishment Rule

01/13/2019

Which customer accounts are covered by the Garnishment Rule?

Cash Deposit At Teller Counter-CTR?

01/13/2019

A customer presents a cash deposit at the teller counter in the amount of $10,000. The teller counts the deposit and discovers it to be $100 over. The customer is made aware and requests the teller to give back the $100. Does this qualify for a CTR since it was handled by the teller while counting the large cash deposit or is it a simple mistake by the customer? We are also considering a SAR for possible structuring by the customer.

Trust that is Not Specified-Revocable

01/13/2019

If a trust account is opened and is not specified to be revocable or irrevocable, does that automatically make it revocable?

CD Interest Paid Monthly Change to Compound

01/13/2019

If a customer with a 4 year CD with interest paid monthly, after 6 months, decides to have it compound annually, what would be the next date for interest to be paid? The opening date was 1-1-2016.

Latest Compliance - BSA Topics

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