Latest Compliance - BSA Topics

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?

CTR for Large Check for Christmas Bonuses

01/19/2020

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?

International Addresses and Online Payments

12/01/2019

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 to Complete a CTR for an Estate

10/13/2019

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 ..."

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.