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#2243965 - 10/13/20 05:02 PM New to Role
Rachel G. Offline
Member
Joined: Oct 2020
Posts: 54
Hi- I am new to my current role with a small community bank. Prior to this I was with a credit union for 6 years that was half the size of the small bank. I am reviewing some of our policies and procedures and it appears my predecessor was quite intense for our size and complexity. However, since I am coming from a CU- I thought I would ask here.
- Do you track and review the cash shipments to your branches as a way to review possible laundering activity? (I already review many other data points, so this seems excessive.)

-Cashier's checks, what are your procedures for them and how are they controlled?

Thanks!

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BSA/AML/CIP/OFAC Forum
#2243968 - 10/13/20 05:39 PM Re: New to Role Rachel G.
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 348
From a BSA perspective, yes on the cash shipments. Examiners also ask for this information during safety and soundness review of BSA.

What do you want to know about cashier's checks? From a security perspective? or BSA Perspective?
- We do not sell monetary instruments to non-customers. Purchasing cashier's checks in amounts less than $10,000 is a common way for money launderers to evade CTR requirements. Our procedures call for the verification of ID for all cashier's check purchases in amounts between 3k and 10k and record retention surrounding it. They are aggregated via our automated system as well. We have a policy requiring customers to deposit the cash first into their deposit accounts for recordkeeping purposes.

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#2243969 - 10/13/20 05:42 PM Re: New to Role Rachel G.
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
Welcome to banking and BankersOnline!

You are learning that banks are regulated more thoroughly and by an party that also isn't your number 1 fan. That said, each institution will need to make a risk based decision on how in depth they go when reviewing BSA/AML. I know that our regulators and independent auditors ask for this information each time so we do have it as a part of our process.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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