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#560838 - 06/01/06 05:35 PM sale of monetary instruments to non-customers
ckme Offline
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ckme
Joined: Sep 2002
Posts: 255
We have had some operation problems,and I have to save the day with some procedures. As far as sale of monetary instruments to non-customers it appears we established a $2,500.00 per business day limit to avoid the MIL. For sales under the threshhold do I NEED to do anything other than OFAC the purchaser and montitor for suspicious activity. Would a log enty with their ID, Name, Address, DOB, SSN etc. for each purchase be recommended?
Thanks

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#560839 - 06/01/06 10:40 PM Re: sale of monetary instruments to non-customers
GuitarDude Offline
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GuitarDude
Joined: Nov 2004
Posts: 5,925
So Cal
IMO, creating a log entry for each purchase defeats the purpose of establishing the $2,500 per day limit in order to avoid maintaining the MIL. You might also be hard-pressed to obtain this info since it is not required, especially if the purchaser knows this.

If you are looking to strengthen what you have described in your post, you might add to your procedure to OFAC screen the payee along with the purchaser.
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