OFAC and Minors
11/27/2022
Should OFAC checks be run on a minor?
A BSA/AML master, Brian brings 20+ years of banking experience to his current role as EVP at Thomas Compliance Associates, inc.
Brian Crow is Executive Vice President at Thomas Compliance Associates, Inc. in Chicago, IL. Brian brings 20 years of prior banking experience to the consulting field. He was most recently Assistant Vice President and BSA Administrator for a suburban Chicago bank, where his responsibilities included preparing the bank's annual BSA risk assessment and audit documentation. Earlier as Operations Officer at the same bank, Brian monitored AML activity, aided in the implementation of the bank's AML software, and designed the bank's authentication blocking program that helped to reduce debit card fraud losses by 95 percent. Brian's responsibilities also included managing the bank's Regulation E claims, managing the bank's courtesy overdraft program, reviewing Reg CC hold notices for accuracy, and processing claims for fraudulent signatures and endorsements.
Mr. Crow has been an education consultant for BOL Learning Connect, conducting webinars that have covered VISA/MasterCard chargebacks, debit card compliance and fraud prevention for hundreds of banks. It was in this role that Mr. Crow was recognized as a Bankers Online Guru in 2011.
Like many of us, Mr. Crow began his banking career as a teller, working his way up to head teller and then branch management responsibilities. He earned a B.A. degree in Theology from Concordia University, River Forest, Illinois. Because of his education background, Brian has been given the unofficial title of "Security Evangelist" as he strives to help financial institutions protect their bottom line from losses related to fraud.
You can contract Brian at b_crow@tcaregs.com.
11/27/2022
Should OFAC checks be run on a minor?
11/13/2022
Are churches and other non-profit organizations allowed to open Certificate of Deposits?
11/06/2022
We are a small bank so just the BSA Officer has access to our system. Are there any compliance concerns with this?
10/30/2022
Our system allows us to use repetitive reasons for clearing alerts. Our auditor recommended we not use these. Why is that?
10/23/2022
Our system allows us to “mass clear” alerts we know are not suspicious. Any compliance concerns with this process?
10/16/2022
How soon after we implement a new system should we have it validated?
10/16/2022
When processing fraudulent debit card disputes with Visa, do we have 5 business days to provide the provisional credit to the customer whether they are a consumer or business customer?
10/09/2022
How frequently should we have a model validation
10/02/2022
Our customer received a call telling them their CashApp account was compromised, and they needed to verify the password. After they did this there were several authorized CashApp transactions. Can we tell the customer they have to resolve the issue with CashApp?
10/02/2022
Our processor says we don’t have chargeback rights since a purchase was made using Visa Secure 3-D. Can we deny the claim since the cardholder’s password was used?