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#2080704 - 05/26/16 07:04 PM Selling monetary instruments to non-customers
gcg Offline
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Posts: 126
Per BSA record keeping rules, exactly what information will need to be retained on non-customers who purchase money orders from us? I've been told it is

* Name of Purchaser
* Physical Address
* Purchaser's TIN
* Date of birth

Is that right or is it just the name? Do we need to get ID? Please tell me where I can find out about it in the law.

Thanks!

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#2080706 - 05/26/16 07:08 PM Re: Selling monetary instruments to non-customers gcg
NotDoneYet Offline
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NotDoneYet
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PA
It is in the FFIEC Bank Secrecy Act/Money Laundering Exam Manual. Look under Purchase and Sale of Monetary Instruments Recordkeeping.

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#2080717 - 05/26/16 07:21 PM Re: Selling monetary instruments to non-customers gcg
Doug Hendrickson Offline
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Doug Hendrickson
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Note that the definition is based on an 'account holder', meaning having an existing 'deposit account' at the bank; so someone who only has a loan with an FI is a non-customer for MI record keeping purposes.

For a non-account holder you need:

name and address of purchaser
ssn or alien id #
date of birth
date of purchase
type of instrument purchased
serial # of instrument purchased
dollar amount of each of the instruments purchased
verification of name and address of purchaser (e.g., state of issuance and driver's license #).
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#2080718 - 05/26/16 07:24 PM Re: Selling monetary instruments to non-customers gcg
thomasj Offline
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Joined: Mar 2001
Posts: 5,062
Pennsylvania
From the manual:

If the purchaser does not have a deposit account with the bank:
Name and address of the purchaser.
Social Security or alien identification number of the purchaser.
Date of birth of the purchaser.
Date of purchase.
Types of instruments purchased.
Serial numbers of each of the instruments purchased.
Dollar amounts of each of the instruments purchased.
Specific identifying information for verifying the purchaser’s identity (e.g., state of issuance and number on driver’s license).

All of this must be kept for 5 years.

Link:

https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_023.htm
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#2080728 - 05/26/16 07:36 PM Re: Selling monetary instruments to non-customers gcg
John Burnett Offline
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John Burnett
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Cape Cod
The purchaser is the individual making the purchase -- the individual in front of the teller. So you treat that individual as a non-depositor if he or she doesn't have an account in his/her name at your bank, even if he/she owns a business or signs on an account in the bank.
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#2080736 - 05/26/16 07:52 PM Re: Selling monetary instruments to non-customers John Burnett
gcg Offline
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Joined: Mar 2007
Posts: 126
Wow! You guys are terrific! Thanks, so much, for the help.

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#2080776 - 05/26/16 10:26 PM Re: Selling monetary instruments to non-customers gcg
Elwood P. Dowd Offline
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Elwood P. Dowd
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Posts: 21,939
Next to Harvey
Selling to noncustomers for amounts above the record retention level is a practice that most banks prohibit as a matter of written policy. Whatever your rationale is, it better be good.
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