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?
Would failure to collect beneficial ownership information at account opening (CDD) or a reason for not needing CDD certification of beneficial ownership be considered a CIP exception?
We received a cash deposit exceeding $10,000 into a deceased person's estate account (personal checking). The executor is an authorized signor on the account. Will the Benefactor for the transaction be the deceased? Will the executor be listed on the CTR as well? Note- the executor was not the transactor.
Is there a timing requirement to return a Cashiers Check that is counterfeit?
If we offer a discount coupon from a local business to a consumer opening a checking account, is that considered a bonus under Truth in Savings?