The new Beneficial Ownership rule adds the CDD Fifth Pillar to the AML program requirements for (a) developing a customer risk profile, (b) conducting ongoing monitoring for reporting suspicious transactions and, (c) updating customer information. What CIP procedures should we follow when a business client provides online banking access for an employee who has the authority to initiate transfers or make bill payments?
What are some of the best ways for our customers to protect themselves against ATM crime?
Our bank requires that all new employees pass a criminal background history check before hiring: however, we understand that temporary employees are not subjected to the same hiring standards. Is this legal?
Are security guards a good deterrent for bank robberies?
Which internal control is better for handling cash in branch office ATM vaults - Dual Control/Dual Custody or Dual Presence?
More than a few of our branch offices house sales and service teams from other bank departments, such as commercial lending. Should those employees receive annual robbery training?
Our branch just started using Teller Cash Recyclers (TCRs). Do they deter criminals? In a robbery situation, what dollar amount should we dispense when the Duress Dispense key is activated? Do you dispense a specific denomination or random bills? Also, how do you handle bait money?
With more of our bank customers using mobile payment apps, such as PayPal, Venmo, Zelle, we are concerned about the increase in potential fraud for our customers and our bank. What steps can we take to mitigate real-time payments fraud?
We have a frequent debate in our organization about how much of a background check is necessary for our employees, and whether or not we should perform background checks when a person is promoted or transferred. Can you please offer guidance on regulatory obligations or industry standards for background investigations?
Does a financial institution have the obligation to screen account beneficiaries for compliance with OFAC regulations?