We have a business that pays their employees by checks drawn off the same account. The employees sign the checks and gives them to the same person to cash the checks for them. The total of all the checks is >$10,000. The person bringing the checks into the bank to cash them, signs under the employee's name on all the checks.
How should the CTR be completed? Is she the conductor for all the employees or is it on her own behalf?
We have a grocery store customer who is an agent for a large money transmitter. The customer offers no other MSB services and is otherwise not considered an MSB other than being an agent of one for this purpose.
Is there any prohibition to exempting them from CTR reporting? Is it generally acceptable to exempt these agents from CTRs?
We have an MSB that has MoneyGram. Does MoneyGram require the MSB to have BSA/AML reporting procedures? Can we ask for those procedures for our customer file?
MSB renewal registration is due by December 31, 2014. In a recent FDIC audit, it was noted that previous (2012) renewal filings were not obtained and only Registration Summaries from FINCEN were in file. I apologize for what seems like a simple question, I am new to this position, is there an easy way to get the renewal filing or should we ask our customer for this?
I have a possible prospect that would like to open a business account here and he has his business license and EIN number. The purpose of the business is Medical-marijuana dispensaries. We are a community bank and I want to know if it is legal to even open in the state of WA. I understand it is legal to have these dispensaries in the state of WA, will we be in compliance?
Does an MSB have to legally provide a copy of their BSA/ANTI Money Laundering Policy Manual to their financial institution when requested?
Can a business owner cash payroll checks against his business account that are made out to his employees? The checks that are being cashed are from the same business account name but drawn on another bank.
Does a check cashing MSB have to check names against the OFAC list? The MSB does no other MSB activities but check cashing. I have called FinCen numerous times and they have not returned my call. Someone at OFAC referred me to Title 31 which also did not address or answer my question.
Can MSBs cash checks made payable to a business?
Our bank has a business customer who printed checks with different remitters. The checks are clearing through one account. Should we close the account? What potential liability could we have?