Vendor Guru Q&A - Operations

Latest Operations - Anti-Money Laundering Topics

Effective date of guidance

07/30/2023

When will the Interagency Guidance on Third-Party Relationships: Risk Management document become effective?

Responsibility for safety and soundness

07/23/2023

Can we shift responsibility for safety and soundness to a third-party service provider in our contract with them?

The scope of the Interagency Risk Management Guidance

07/16/2023

Are the areas addressed in the Guidance limited to laws and regulations addressing fair lending and prohibitions against unfair, deceptive or abusive acts or practices?

Tailored approach to risk management

07/09/2023

Does my small community bank need to adopt the same third-party relationship risk management approaches as larger, more complex banking organizations?

Risk management life cycle

07/02/2023

Can the details provided in the Guidance with respect to the aspects of the risk management life cycle be used as a check list for my bank’s risk management plan?

Regarding Model Validation of our AML system, we have one main system that does our overall OFAC checks. We have other systems that do OFAC checks for wires, IATs etc. During a model validation, is it the expectation that all OFAC systems be validated, or just the main system? Could this be based on risk?

Reporting joint account deposits

06/11/2023

Are there any changes on how a single reportable deposit to a joint account is to be reported?

Reporting multiple transactions

06/06/2023

How should we mark Item 3 to report multiple transactions?

Can we refuse to bank someone? De-risk?

06/04/2023

What is De-risking?

Sole proprietorship owned jointly by spouses

06/04/2023

If our state allows spouses to jointly own and operate a sole proprietorship business without forming a partnership, will we treat a sole proprietorship account as a joint account when filing a CTR for a reportable transaction of the business?

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Indemnity Bond for Lost Check

10/01/2023

If a bank mails out a Cashiers Check as proceeds on a loan and that Cashiers Check is lost, who signs the Indemnity Bond for Lost Instruments? Would the bank (purchaser), customer (who asked for the loan and to pay the different merchants) , or the credit card company (Payee)?

Latest Operations - Anti-Money Laundering Topics

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