Can you refer me to the guidance for assessing the BSA risk for coin operated amusement machines operated in convenience stores who happen to be a customer of our community bank?
We are in Oklahoma. Our account owner has died, and her beneficiary is also deceased. Who gets the funds? Will it need to probate? The amount is less the $1000.00 and the family can't afford to see a lawyer.
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?
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?