Our teller line keeps a log and a spreadsheet of the collectable coins they sell. The head of the teller department asked me if the log has to contain the name of the person purchasing the coin. I have no idea and can't seem to find the answer. How does everyone else handle this?

Petcat, I'm lost - what type of collectable coins are they selling?

If it's Presidential coins, and the sale is $10,000. and under I do not believe there is a requirement other than that imposed by the bank.

If they are collectors and selling their personal stash on bank time, that's another issue.

We never kept the name of the purchaser. Our log was used to track and audit the coins sold/remainng.

My answer/question will tell you about our compliance mindset - do you offer these items to non-customers, and if so do you check OFAC? I need to contemplate this one....obviously, everything is risk-based, so as previously mentioned, how large are the sales? I think that would drive my procedures...Any sales over a certain $$ amount should probably result in more overview than a $5 sale might require.

Yes I am talking about coins such as the presidential coins. We never sell more than one or two at a time so the dollar amount is very small. We are a very small community bank in a small town so we do mostly sell only to customers but we are aware that if we sell to a non-customer we must OFAC. It has never been our policy to record the customer name but someone mentioned it and we wanted to make sure we were following correct procedures.

Petcat, I think of it as if someone were to walk into a branch and ask for change for $5.00, or a roll of nickles. We would definitely not ask for identification under those circumstances. It is money, but thousands below any reporting threshhold, and IMHO, costing the bank a lot more than any benefit or risk.

If the bank wanted to maintain an inventory, then a log like Trail mentioned would be helpful - you would know when to re-order. In our case, the tellers try to get rid of the coins as fast as possible.

Unless you wanted it for future marketing purposes, or simply for coin sales account/gl reconciliation, I cannot imagine any other need for having the name of the purchaser (unless they of course bought 43k worth of silver santa coins in cash).