Is there a better way to ensure we are opening accounts that will not be a future liability?
I’m satisfied with our current system. Why should I switch the way we verify customers?
I overheard an employee recommending to a customer to deposit part of a deposit one day and the rest of the money the next day, therefore avoiding the filing of a CTR. What action would need to be taken on this employee? I need to make sure that all the bases are covered and all the reports needing filed are filed.
If we intend to close a checking account due to suspicious activity (SAR has been filed), how many days notice must we give the customer when they have direct deposit to the account?
Does the bank courier need to receive annual training on BSA? He is employed by the bank but does not process transactions or have a desk/office in the bank?
A bank employee that acts as a conductor and fully understands BSA/AML, backs out of a $20,000 split deposit after being advised that a CTR must be filed. Would this individual be violating the reporting requirements?
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?
I'm the compliance officer at a small community bank. We do not offer remote deposit capture, but from what I understand, some of our bank's commercial deposit customers have gone out on their own initiative and obtained RDC services from various third parties. Our customers are then using this platform to make deposits to their accounts at our bank. This would seem to involve risks to our bank, but I'm getting a lot of push-back from the sales side, that because our bank had nothing to do with the customer's decision to enroll in or obtain these RDC services, the bank has absolutely no risk. I'm not as convinced about that. Any help and or guidance appreciated.
Why is it that most banks that originate outgoing wire transfers require a physical address (no PO boxes) for the beneficiary? Is this a compliance requirement and if so, where is it established? I have looked at Reg J, the UCC, the BSA exam manual and the travel rule without much luck. The latter proved more helpful than the others, but still offered little justification for the requiring of the beneficiary's physical address. In this regard, the rule states that the originating bank is only required to retain "beneficiary information provided by the requestor" which may or may not include an address. Any help in determining how and/or why this no "PO box policy" was derived would be greatly appreciated.
Can a customer who has had SARs filed on them for a suspected BSA suspicious activity be eligible for a phase II exemption?