I just received a memo from one of my SVPs, stating that our bank has been contacted by our local law enforcement (a named individual provided) to setup a DDA account for an individual, and that the account will be apparently used to capture other individuals illegally sending money to the Middle East. The memo states that the FBI is also involved (no FBI agent's name disclosed). It further instructs us (Audit Dept) to adhere to all BSA reporting requirements, CTRs,CIP etc.

Has anyone else out there been subject to such a request??? What type of documentation did you require prior to opening? Do you keep a separate "confidential" file on this person? What docs do you keep in the file?

I'm just a little panicked and a little uncomfortable at this point and not quite sure how to proceed. Like I said initially, ALL I received about this matter was a MEMO! Help!

I know we have had this question before. You certainly need to contact your police department to see if this is legitimate before you cooperate.

Any suggestions on what I should search on?

I did a search and did not find it. You might send a privat message to Andy Z to see if he remembers.

My answer was assuming that this was the local police since he said local law enforcement. I guess I left too much to chance in my answer, but I know this was answered before. Yes, I agree, get a number from the person who has approached you--independently verify that the number is a law enforcement number. Just remember that just because someone answers the phone "Detective Jackson" does not mean that it is Detective Jackson you are speaking with. You may have to actually go to the police department and meet face to face. You don't want to blow an undercover operation, but you do need to make sure who you are dealing with.

I have had these types of accounts and we got confirmation of the operation from their superiors, about two or three levels up, on letterhead. Furthermore our policy required that Senior Management be made aware of these types of accounts, and the Bank Legal Counsel made a few calls to verify. Hope this helps you.

I would probably want to contact our regulators, too. The kinds of transactions that are the target of this operation might involve OFAC entities, or SAR-able activities.

You have to remember, under the patriot act, you could be charged . Do not contact the person who opened the account. You cannot give them information or act in a way to tip them off that they are the subject of an investigation. Tread carefully.