I started in BSA a few years ago and I built an Enhance Due Diligence program for higher risk customers with monthly transaction review and then yearly comprehensive review of the business and its expected vs actual activity. At the time I found a really clear outline of expectations in the BSA Manual and now I can't find anything related to EDD at a all. Did this get removed? Anyone else experiencing this?
What is the record retention of vault open/close logs?
Do your lease agreements have alterations, white-out changes or typed mistakes?
Does a business customer have to return monies for a transaction while a dispute by the company is being processed?
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?