I have a customer that appears to be processing personal transactions through his business account with FanDuel internet gambling site. FanDuel operates under a specific exemption written into the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA) that allows for fantasy sports contests. Am I correct in thinking that the use of FanDuel is not a violation of Reg GG? Also, is conducting personal transactions through a business account SARable?
We filed a SAR for possible structuring. After the 90 days we found there to be no other cash transactions. Now it has been eight months and we suspect this same customer for structuring again. Do we file a new SAR or recurring from the one we previously filed eight months prior?
Filing Institution Note to FinCEN in SAR form -- I'm aware there is a 50 character limit, but is there any indication that we
should only be entering one advisory at a time or are multiple entries allowed if they all fit?
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?
Why does our financial institution no allow people to deposit cash into another person’s account?
If our customer uses a personal account to run a business is this a problem?
If we see a Board Member changing $5, $10 and $20s for $100s on a regular basis should we alert our BSA officer?
If the customer asks me a question on structuring is that reportable on a SAR?
If the customer attempts mortgage fraud should we tell BSA?
Some taverns/bars are involved in "Sporting Pools" aka: Football Pools, Office Pools, Super Bowl Pools, etc.
Does FinCEN encourage SARs to be reported for a business involved in such activity? Gambling is not legal in my area.