Most Popular Compliance Content
CTR Dilemma- Proof of Funds for Transfer
11/14/2021
We have a CTR dilemma. A customer came in with $20,000 cash. - The funds were first deposited into his account. - He then wanted to purchase a cashier check for $7,000. - He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He is not on the family member's account. The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer? We also plan on filing a SAR.
Unemployment /Economic Impact Payment Fraud
11/14/2021
FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?
Compliance Program for Credit Union
11/07/2021
I am new to compliance and looking for assistance in creating a compliance program for the credit union I work for. We are a small CU and a dedicated compliance officer role is new here. Would appreciate any help or guidance you can offer.
Compliance Program for Credit Union
11/07/2021
I am new to compliance and looking for assistance in creating a compliance program for the credit union I work for. We are a small CU and a dedicated compliance officer role is new here. Would appreciate any help or guidance you can offer.
Return Wire when Originator is not on SDN?
11/07/2021
Shall we return a wire sent from Russia when the originator is not on SDN but the originator's bank, SBERBANK is on the e Sectoral Sanctions Identifications List?