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Latest Operations - Bank Secrecy Act Topics

Marijuana Limited SAR/Marijuana Priority SAR

09/10/2023

Do you have to file a Marijuana Limited SAR or Marijuana Priority SAR if you discover one of your customers works for a marijuana related business (MRB) but is not the MRB? Hypothetically if you find out one of your customers works at a growing facility of marijuana but does not own it, do you have to file?

Effective date of guidance

07/30/2023

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

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?

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?

Reporting a cash deposit and currency exchange

05/28/2023

John Jones makes a cash deposit of $9,600 to the account of his hardware store, Jones Hardware, Inc. He also gives the teller five $100 bills and obtains $500 in $20 bills in exchange. Is there any change to how we will report these transactions?

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Technical 314a Fields

12/03/2023

Does the FinCEN 314a list have specified field definitions? i.e., field lengths.

One Sig Card for All Accounts

12/03/2023

Is it required to have a new signature card for each new account under an existing a person's CIF? If not, is there an example of a CIF card just for the signatures?

Unauthorized or Chargeback?

11/26/2023

A cardholder let's, lets call him Grandson A, use grandma's card to make a Temu purchase. Her other grandson, B, never had authorization to use the card. Grandma begins to get unauthorized or unfamiliar charges from Google and CashApp on her account. She states she thinks Grandson B took her card out of her purse, made the transactions, and placed the card back. Are we able to file a chargeback on the charges based off the her assumption that Grandson B took the card info?

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