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#465516 - 12/05/05 03:01 PM out of country customer
beegee Offline
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Joined: Feb 2004
Posts: 1,096
We have a customer who will be living abroad but wants to continue his relationship with our bank. He will be wiring funds to and from his accounts with us.

What are some safeguards we can put in place to protect all parties given that the activity will be faceless?

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General Discussion
#465517 - 12/05/05 04:48 PM Re: out of country customer
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,503
On the Net
BSA increased monitoring and a higher risk rating, depending on where the customer goes and the types of transactions you expect, and see.

If this is SS deposit in, and wire out, no biggie. If this is $500M in and $500M out, biggie.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#465518 - 12/05/05 08:09 PM Re: out of country customer
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Authentication of the customer's wire instructions could be a challenge. You need to set up in advance how the customer will transmit wire instructions to you, and how you can verify the instructions are legitimate. One way to do this is to set up a list of endpoints to which your customer expects to wire funds (for instance, perhaps there are only two overseas accounts he will use).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#465519 - 12/05/05 09:13 PM Re: out of country customer
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,534
Pulling people out of the ditc...
you may also want to look at PIN based transactions, with a changing authentication key for each transaction. Get to bit a tad pricier than using the same test key over and over, but could save you from losses in the long run
Providing alternative truths since the invention of time

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#465520 - 12/06/05 12:04 AM Re: out of country customer
homestar Offline
Diamond Poster
Joined: Feb 2001
Posts: 2,245
US of A
If you decide to continue the relationship, be sure you know where your customer lives. OFAC has rules you must follow for certain nations.

For example, it's OK for a bank to hold an account for an owner who is living in Iran, however, you can't let the customer directly conduct transactions while they live there.
"If you want to tell people the truth, make them laugh, otherwise they'll kill you." ~ Oscar Wilde

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