We suspect a customer is being used as a mule and recently received a large ACH credit. The next day, he wanted to send an international wire with the proceeds from the credit. His explanation of where the funds came from and what they are being used for has changed several times; therefore, we froze the account and have the funds from the ACH credit on hold. Since we suspect he received the funds fraudulently, are we under any obligation to release these to our customer?
Would failure to collect beneficial ownership information at account opening (CDD) or a reason for not needing CDD certification of beneficial ownership be considered a CIP exception?
Is there a timing requirement to return a Cashiers Check that is counterfeit?
If we offer a discount coupon from a local business to a consumer opening a checking account, is that considered a bonus under Truth in Savings?
Is there any regulation or best practice that says the fact that a person is a customer of a particular bank is private information? My local police department is wanting continual access to my exterior cameras to help them fight crime. I am concerned about privacy issues for customers (among other things).