This is exactly what we did....and its working out pretty well...
This is the process that we're following:
1) Print list of all business' by branch since 10-1-03
2) Managers are to identify high risk business based on FDIC's official list of High Risk Business'. Once all High Risk Business' are identified, a new report will be printed to show only high risk business'
3) Managers are to take the new High Risk Business list and identify which accounts are considered MSBs (this was the difficult part-managers had to pull sample deposits to see if any checks were cashed, etc...)
4) Once all MSBs are identified, managers are to check the FINcen Website to see if they are registered.
5) If not registered, managers are to send a letter telling them to register.
6) Follow up in 45 days...If no registration, SAR
Thats it in a nutshell....were on step 5. Business', for the most part, are being cooperative.
Next comes getting AML procedures, etc, etc.....
Man I just love this stuff!
"Saying what we think gives us a wider conversational range than saying what we know"