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Latest Compliance Topics

Sanctions List for Individuals vs. Countries

10/31/2021

We have a customer who wants to wire money to Pakistan. I don't understand the sanctions list. If there is a list of entities shown, does that mean that we shouldn't send the wire? Is the sanctions list specifically for individuals or countries?

HMPL Error Correction

10/24/2021

We found an HPML in our audit. There is no escrow set up. What can we do?

Noncustomer Direct ACH Deposits

10/24/2021

May a noncustomer have direct ACH deposits made into a customer's account without that person being on the account? What are the potential problems if we find this?

HMPL Error Correction

10/24/2021

We found an HPML in our audit. There is no escrow set up. What can we do?

List of Board Policies (Regs/Acts)

10/17/2021

I was wondering if there is a list of board policies that financial institutions are required to have (regulation/acts) along with how often they should be reviewed by the board?

New Escrow on Existing Loan

10/17/2021

We had a customer ask to start a voluntary escrow account on an existing loan. Do we need a new agreement?

Military Identification Card

10/17/2021

If a customer presents a military identification card and has no other form of ID, it is my understanding is you cannot make a copy of Military ID's. What other forms can be used? This person does not drive and has no transportation to get to the DMV. He does have an expired TX DL but that is all.

Risks for Online Account Opening (CIP)

10/17/2021

How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?

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Unemployment /Economic Impact Payment Fraud

11/14/2021

FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?

Compliance Program for Credit Union

11/07/2021

I am new to compliance and looking for assistance in creating a compliance program for the credit union I work for. We are a small CU and a dedicated compliance officer role is new here. Would appreciate any help or guidance you can offer.

Return Wire when Originator is not on SDN?

11/07/2021

Shall we return a wire sent from Russia when the originator is not on SDN but the originator's bank, SBERBANK is on the e Sectoral Sanctions Identifications List?

Debit Card Returned, Card Info Used

11/07/2021

If after the suspect gave “Tiffany” her card back, he used her card number to make an online purchase without her knowledge, is she still liable even though he gave her the card back?

Compliance Program for Credit Union

11/07/2021

I am new to compliance and looking for assistance in creating a compliance program for the credit union I work for. We are a small CU and a dedicated compliance officer role is new here. Would appreciate any help or guidance you can offer.

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