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#1521018 - 03/11/11 11:10 PM source of funds
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma
When opening a new account, such as a CD is there any requirement to identify the source of the funds being deposited?

I know it would be a good practice but I have been told it is a requirement.

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BSA/AML/CIP/OFAC Forum
#1521022 - 03/11/11 11:28 PM Re: source of funds parr04
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
No, it is not required by regulation.

It is, however, dependent on your Customer Due Diligence policy and procedures. So if your policy and procedure state that you will record that information, then it is required for your bank.
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#1521045 - 03/12/11 11:55 AM Re: source of funds parr04
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Ask for a citation to law or regulation or even a "favorable mention" in the BSA/AML manual. If the person knows what he or she is talking about they will have it... Don't chase someone else's rabbit.
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#1521107 - 03/14/11 12:57 PM Re: source of funds Elwood P. Dowd
A_G Offline
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Are they perhaps referring to (11) of this?
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#1521129 - 03/14/11 01:38 PM Re: source of funds A_G
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Method of payment would be cash, check, another deposit, etc. "Source of funds" means where did the money come from; e.g. earnings, sale of assets, etc.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1521133 - 03/14/11 01:41 PM Re: source of funds Elwood P. Dowd
A_G Offline
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Joined: Jul 2004
Posts: 18,989
Oh, I'm not opining they are correct by any means. Just a thought on what they are, as you point out, incorrectly citing.
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With the lights out, it's less dangerous.

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