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#1071243 - 10/27/08 04:19 PM Account opened for "Reward for Missing Person"
Lele Offline
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Lele
Joined: Feb 2007
Posts: 825
In the Sun
The bank opened an account for a customer that has a missing daughter. The mother says that the money will be used as a reward for information. I rated this High Risk but what else should I do? Is the bank responsible for monitoring how the funds are used? What other information should the customer provide? They did get a EIN.
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#1071427 - 10/27/08 07:13 PM Re: Account opened for "Reward for Missing Person" Lele
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
I would monitor how the funds are used in case there is something obvious that does not make sense.

I would expect to see checks out for expenses such as printers for flyers and brochures, and newspapers ads to find the missing person.

You have an EIN so I cannot think of anything else you need.... other than I think I would print newspaper articles to support the missing person story.

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#1071561 - 10/27/08 09:13 PM Re: Account opened for "Reward for Missing Person" Lele
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If your "high risk" rating is connected to your AML system it does not belong on this account. The account carries legal and reputational risk for sure, but no BSA/AML red flags.

Note that Chapter 496 of Florida statutes contains explicit requirements for accounts where people are soliciting contributions from the public. Unless a formal trust and trustee are part of your package, you are probably going to have to unwind this.
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#1071599 - 10/27/08 10:39 PM Re: Account opened for "Reward for Missing Person" Elwood P. Dowd
Lele Offline
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Lele
Joined: Feb 2007
Posts: 825
In the Sun
By 'Unwind' are you saying to close this account?
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