Latest Compliance - Money Laundering Topics

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?

Customer Writes Check from Bank A/Deposits Bank B

11/24/2019

We have a customer who writes checks from his account at our bank (Bank A) and deposits them at Bank B. The account is overdrawn every morning. He then wires money from Bank B back to Bank A to cover the overdraft. The account is not being used as a business operating account. Each day the amount involved gets larger. How should we address this? Is there a specific Regulation we can site for closing the account?

Suspected Fraud- Funds from ACH Credit on Hold

09/08/2019

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?

USA PATRIOT ACT Policy/Procedures

11/22/2015

I attended Ken​ Golliher​'s seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to​ address Section 311 ​(Special Measures) ​ of the US​A​ PATRIOT Act in our policy/procedures. ​I was hoping someone could weigh in on this for me.

BSA/ANTI Money Laundering Policy Manual (MSB)

06/25/2012

Does an MSB have to legally provide a copy of their BSA/ANTI Money Laundering Policy Manual to their financial institution when requested?

Training Materials for USA Patriot Act

08/22/2011

I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?

Regs Covering Non-Signer Depositing Checks

06/20/2011

Can you allow funds payable to someone to be deposited in an account that they have no ownership or withdrawal rights? What reg covers this? We have customers ask us to deposit checks payable to "John Doe" into account for "Jane Doe" where Jane is the only owner/signer. We always explain to them that we do not allow it because John would not be able to withdraw the funds and we do not want to take a chance on John holding the bank liable because he did not receive benefit of the funds. There is often a suspicion that John is trying to hide the funds from the IRS or because of legal judgments. We would like to know which regulation or act specifically addresses this so we can have a basis for our policy. Does this fall under money laundering under the BSA?

BSA Exemption Review Form

05/15/2009

Red Flags - Highest Risk Customers

02/02/2009

What are the highest risk customers for money laundering and what are the specific red flags for unusual transactions within that customer group?

Integrating Compliance Programs into your Operational Risk Management Program

12/08/2008

Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?