Item #2 on the SAR
11/03/2019
What is a note to FinCEN?
Deborah Crawford
Bio:
Deborah Crawford is the President of gettechnical inc. She specializes in compliance and regulations for the deposit side of financial institutions. Her 27+ year career in banking and training began at Hibernia National Bank. She has been a seminar leader for many state associations and credit union groups across the nation. She has Bachelors and Masters degrees from Louisiana State University.
Questions Answered
Aggregated transactions versus Multiple transactions on a CTR
11/03/2019
When do we check aggregated or multiple transactions?
Do we file on every cyber event? A SAR?
10/27/2019
What must be in a mandatory or voluntary cybercrime filing?
Does every NRA have to have an FTIN?
10/27/2019
Do we have to look back to those customers already on our books for Foreign Taxpayer Identification Numbers (FTIN)?
IOLTA and CTR who goes where?
10/27/2019
On an IOLTA do we record the owners of the funds or the attorneys on cash transactions on a CTR?
FBI, DEA….who can get supporting documentation?
10/20/2019
Who can receive supporting documentation?
Private ATM withdrawals on CTRs
10/20/2019
If we have a customer have a private ATM withdrawal put them over $10,000 do we complete a CTR?
Is a citizen of Puerto Rico a US Citizen for taxes?
10/20/2019
Is a citizen of Puerto Rico a US Citizen or a nonresident alien for tax purposes?
General ledger numbers on CTRs?
10/13/2019
Do you put your bank’s general ledger account number on a CTR?
US Person and NRA on account? Whose TIN?
10/13/2019
If there is a US Person and a Nonresident alien on the account, do we have to have a FTIN?
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