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#1618328 - 10/20/11 07:15 PM MSB CTRs
Chosen Offline
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Joined: Jan 2005
Posts: 36
Texas
Is a bank allowed to review CTRs filed by a customer MSB as part of due dilligence? What if a bank is requesting copies from the MSB?
Last edited by John Burnett; 10/20/11 07:22 PM.
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BSA/AML/CIP/OFAC Forum
#1618331 - 10/20/11 07:18 PM Re: MSB CTRs Chosen
John Burnett Offline
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John Burnett
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Cape Cod
Candidly, I'd resist the temptation to become your MSBs' BSA/AML enforcer. It's not part of the job description for banking MSBs. The MSB should be able to provide you with documentation of an effective review of its AML/BSA program; you don't need to be part of it.
Last edited by John Burnett; 10/20/11 07:22 PM.
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#1618332 - 10/20/11 07:18 PM Re: MSB CTRs Chosen
Chosen Offline
Junior Member
Joined: Jan 2005
Posts: 36
Texas
Topic is meant CTRs
Last edited by John Burnett; 10/20/11 07:22 PM.
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#1618334 - 10/20/11 07:23 PM Re: MSB CTRs Chosen
John Burnett Offline
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John Burnett
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And I have gone back and edited the Subject line to reflect that fact, but I was responding to the question you raised, not the subject line.
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#1618462 - 10/21/11 10:25 AM Re: MSB CTRs Chosen
Elwood P. Dowd Offline
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Next to Harvey
Right up to the point where it asks for copies of SARs, a bank can require anything it wants from an MSB customer; e.g. policies, procedures, CTRs, audit reports, examination reports, etc. At any point along that path the MSB is entitled to tell the bank to take a hike and simultaneously begin a journey of its own to a different bank.

The amount of intelligent oversight a bank exercises over an MSB is dependent on the level of risk it perceives. Asking for all of the above or even CTRs would suggest this MSB is keeping you awake at night; i.e. they are higher than "high risk." This isn't due diligence, it's an investigation.
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#1618806 - 10/21/11 07:42 PM Re: MSB CTRs Elwood P. Dowd
John Burnett Offline
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John Burnett
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Cape Cod
Corollary comment: Unless you have reason to have elevated this MSB to a higher risk plateau, asking for copies of its CTRs is serving no end other than making your job more challenging than it needs to be, and unnecessarily increasing the costs of maintaining the MSB as a customer.
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