Thread Options
#2036956 - 09/02/15 08:19 PM Mission Church wants bank to issue debit cards to
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
foreign nationals in another country where the church conducts its operations. They are not signers on the account. The business line called me to ask about CIP for the debit card holders. I told them the debit card holders do not meet the definition of customers, so this is not a CIP issue. However, it could be a fraud risk issue, so we may want to obtain some sort of ID for them, like a local drivers license or ID card. Did I get that right do you think?

Return to Top
Deposits and Payments
#2036966 - 09/02/15 09:12 PM Re: Mission Church wants bank to issue debit cards to Daisy Doodle
kw004h Offline
100 Club
Joined: Nov 2009
Posts: 219
Chicagoland, IL
Will you be screening the names of these customers for OFAC? I think this presents an OFAC and sanctions risk to you, depending on how you screen your customer base.

Return to Top
#2037520 - 09/08/15 04:07 PM Re: Mission Church wants bank to issue debit cards to Daisy Doodle
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,296
Cape Cod
There is also the very real threat of money laundering or terrorist financing. Too many seemingly beneficent charities have been connected with AML and terrorist financing to simply assume that even a mission church, as much as you don't want to believe it could be involved, should get a "pass" on simply letting this proposal go unchallenged.

You need to know a lot more than the skeletal facts you have provided here.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top

Moderator:  John Burnett