Vendor Guru Q&A - Compliance

Latest Compliance - Money Laundering Topics

Big deductions on paycheck red flag for human trafficking?

03/28/2021

We have a customer who is a young and receives a very small paycheck. It looks like some really big deductions are held by the employer. Is this normal?

Funneling Cash to Central Account?

03/21/2021

Why does our financial institution no allow people to deposit cash into another person’s account?

Using personal accounts for business purposes? Is that bad?

03/14/2021

If our customer uses a personal account to run a business is this a problem?

Board of Director and SARs

03/07/2021

If we see a Board Member changing $5, $10 and $20s for $100s on a regular basis should we alert our BSA officer?

Felony Moments and BSA

02/28/2021

If the customer asks me a question on structuring is that reportable on a SAR?

Attempts and SARs?

02/21/2021

If the customer attempts mortgage fraud should we tell BSA?

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 USA PATRIOT Act in our policy/procedures. I was hoping someone could weigh in on this for me.

Premium Content View All

Identifying Financial Activity from Human Trafficking

In July 2018, the Financial Action Task Force (FATF) and the Asia/Pacific Group on Money Laundering (APG) issued a joint report, Financial Flows from Human Trafficking, updating it July 2011, FATF

FinCEN and Regulators to Focus on Banks for Money Laundering Violations

A recent debate in the Senate Banking Subcommittee focused on how banks may be culpable in money laundering activity, and participants suggested that regulators may be lax in the enforcement of exi

Church/Credit Union: Non-government Organizations?

08/01/2021

We are going back and forth as to whether or not a credit union or a church are actually considered non-government organizations? Although we know that they are non-profit, I have read conflicting information and am trying to settle this internally.

Record Retention for Debit Card Dispute Docs

08/01/2021

How long do we need to keep debit card dispute docs? (What is the time of retention?)

Advertising-more than ECOA, TILA, TISA and Fair Housing

08/01/2021

Is following the standard Regs, B, Z, DD and fair housing going to ensure advertising compliance?

Handling Reg E claims on older transactions.

07/25/2021

If an EFT claim is made long after the statement is sent showing the transaction, the rules of investigation don't apply. So why do we investigate any of these claims?

Compliance Info on Paper Checks

07/25/2021

I was wondering if you could point me in the right direction as to where to find more information on compliance for paper checks? Whenever I place a stop payment on a paper check, there's a disclosure that says "this request will expire in 6 months in order to comply with regulatory requirements." For the customers who ask for a more in-depth answer, what can I tell them?

Latest Compliance - Money Laundering Topics

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