Latest Compliance - BSA Topics

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.

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).