We have a prospective client that is a small car dealership. They don't have a formal AML program but they do file 8300 forms as required. They're coming over from a "big bank" and they were not asked for that and so they're a little miffed that we are requesting a copy of that. Not sure if we'll run into issues if we open the account without that. Comments and thoughts welcome.

so you are considering bringing on a customer that already has indicated they don't want to provide the information your bank is requesting for account opening? and you're continuing this disucssion with this prospect why?

if it were me, i'd pass on this one

Its not that they "won't" provide it, its just that they don't have a formal written program to provide. I'm just curious if its really even a requirement since we don't really have any car dealerships right now. I've given them a detailed questionaire on their cash activity and 8300 forms filed in previous 12 months. I guess I'm asking those of you who bank car dealerships, what do you require and do your regulators have certain expectations?

Under what regulatory authority does a car dealership need an AML program?

That would be my question. Filing 8300 form is one thing. A full blown AML program is not required under any rules I am familiar with.

I agree with Randy and KB. Your FI is not this customer's de facto regulator. I'm not even sure how you would monitor whether a dealer is filing form 8300 accurately? Think about it. Are you doing this for attorneys? Or other professionals who could receive a payment in excess of $10,000?

I would stick to filing CTRs and if appropriate, SARs on this customer.

I couldn't locate anything either, but at a recent BSA seminar, it was suggested that NBFI clients have an AML program in place. Car dealerships fall under that category. Since this is our first dealership client in a while, I wasn't sure if the expectations for EDD had changed so I'm glad to hear that this is not required. Thanks for your input folks.

A car dealership is an automatic NBFI? Really ?

Accepting cash in excess of $10,000 does not make you an NBFI. Unless there is more to the story, I don't see how this customer is an NBFI?

There was some "talk" about a requirement but I do not think it went anywhere (when this came out).

http://www.treasury.gov/press-center/press-releases/Documents/sellers.pdf