Do any of you have a policy about non-customers purchasing cashiers checks? Will you allow the purchase with cash? With checks in collected funds on your bank only? Not at all?

Our policy states that we will not sell any monetary instruments to non-customers. It also states that we will not do any wire transfers for any non-customers.

Sure, we sell MI to non-customers. CCs are $4 each. However, then we must check our MITR against the bi-weekly 314a list.
We do not wire for Non-customers.

No we do not. I always thought it was because we have some "cashless" branches. It may also have to do with the complications of replacing them (surety bonds and so forth). Other MI we do sell to noncustomers.

We will sell up to $1,000 in money orders or traveler's checks to non-customers with proper ID. We will not sell a cashier's check to a non-customer.

No monetary instruments are sold with cash in any amount. In very limited circumstances, with a good reason and appropriate approval and exception may be made IF documented

No, we do not sell to non-customers. I am curious though about the comment on checking against the 314 list. Do you keep this information in electronic form?

Money order Yes, Cashier's check, No.

We would sell money orders to non-customers, but we made the fee so high that none of them wanted to buy one.

Our BSA policy will likely soon restrict the sale of negotiable items to customers only. We currently limit the sale to items under $3k so we don't have to mess with MIPLs.

We do not sell any negotiable instruments to non-customers.

I'm not certain this is responsive, but the new BSA Examination manual makes pretty specific suggestions regarding check sales:

Banks selling monetary instruments should have appropriate policies, procedures, and processes in place to mitigate risk. Policies should define:
• Acceptable and unacceptable monetary instrument transactions (e.g., noncustomer transactions, monetary instruments with blank payees, unsigned monetary instruments, identification requirements for structured transactions or the purchase of multiple sequentially numbered monetary instruments for the same payee).
• Procedures for reviewing for unusual or suspicious activity, including elevating concerns to management.
• Criteria for closing relationships or refusing to do business with noncustomers who have consistently or egregiously been involved in suspicious activity.

If I was going to the trouble to reduce all of the above to writing, I would also address the issue of verifying available funds and perhaps instructing the employee to draw the transaction to the attention of a supervisor if the amount of the check exceeds the average balance in the account.

The MITR information is not in electronic form. The teller supervisors check the 314a list against the MITR log every two weeks or when they receive the 314a listings. There are so few monetary instruments sold for cash between $3M-$10M, it is pretty easy to check the MITR for any unlikely matches.
Within the context of selling monetary instruments to non-customers, the 314a lists only have to be checked against $3M-$10M cash items.
We don't do wire-transfers for non-customers so those don't have to be checked with the 314a lists......because we do the 314 check accross the whole customer database, so we only have to worry about those pesky monetary instrument purchases.

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No, we do not sell to non-customers. I am curious though about the comment on checking against the 314 list. Do you keep this information in electronic form?

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