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?
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?
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.
Does an MSB have to legally provide a copy of their BSA/ANTI Money Laundering Policy Manual to their financial institution when requested?
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?
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
by Brenda S. Canterbury
Senior Compliance Manager, Specialty Businesses
RBC Bank (USA)
What are the highest risk customers for money laundering and what are the specific red flags for unusual transactions within that customer group?
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?
Where can I find the verbiage for the CIP notice?