We are debating Item 24 on the SAR form, Financial Institution TIN and Account affected. The scenario is this - a bank customer cash structured his transaction by cashing two checks on two separate days drawn off of another bank customer. Do you include the account number of the two checks cashed even though the cashier has no ownership to the account?
Does a Money Service Business (MSB) who is registered through the state Nationwide Multistate Licensing System (NMLS) still have to register as a MSB separately with FINCEN?
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?
Regarding OFAC compliance, should my 314a scans of wire activity include both domestic and international wires or just foreign wires sent or received?
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.
Can you tell me where to find guidance on, or when to actually do, when a Currency Transaction Report was filed by mistake?
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?
Is it a requirement to gather Beneficial Ownership information on loan guarantors?
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?
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?