As it pertains to the Beneficial Ownership Rule, we have a municipality that wants to open an escrow account for a business. The business is an LLC, but
the municipality is in charge of the funds. For BSA purposes, do we need to obtain all the normal documents for the LLC including all info on owners?
How in depth do we need to dig for this? In this case the LLC is not an existing customer of the bank.
Does a publicly traded company need to have a CIP filled out for the company and the signers?
We just learned our customer is deceased; he passed 4 months ago. It’s a sole-owner account. The account has a small balance, but we’ve been contacted by an insurance company saying that we have to return the last 3 payments because payments should have ceased when the customer died. Returning these will overdraw the account, and we likely will have to return funds for SSI payments too. Do we have to comply with the insurance company?
I am not sure what structuring is anymore?
We have a business account with approximately 8 authorized signers and a qualifying transaction from the night drop. On the CTR, I understand that the Night Drop explains why you have not identified a conductor, but do I list all the authorized signers on the account (all parties benefit from deposits) or just the business?
If an applicant for an account passes all the BSA and CIP qualifications (ID verification, chexsystems, credit report) to open an account, yet the bank employee has an uneasy feeling or is suspicious of their intentions, are we able to decline the applicant for the account? If not, what options do we have to protect the institution from a loss? If so, what should we provide as the reason for the decline on the notice of action letter?
I have implemented AML software and need to implement a procedure for alert and exceptions review. How do I go about this especially with the software being new?
Under the final CDD rule effective 5/11/2018, is an auto-renewed CD for a legal entity considered a "new account" that requires a new certification of beneficial owners?
I have a SAR filing question, regarding NAICS codes. We have an internal Quality Assurance Department that reviews all SARs filed in our BSA/AML Department. We are being advised to apply NAICS codes based on the type of industry an individual is employed in; For example we have an individual that is employed as a SCHOOL NURSE – I believe the NAICS code should be 6213 “Office of Other Health Practitioners." However, my QA team is suggesting we use NAICS code 611 “Educational Services.”
Anesthesiologist with Conta Costa County we used 6213 “Office of Other Health Practitioners” – my Investigator was told to change this individuals NAICS code to 923 “Public Administration/Administration of Human Resource Programs, because the individual is employed with the County of Conta Costa. Or Accountant for New Beginnings we used 5412 “Accounting, Tax Prep” – my Investigator was told to remove 5412 and instructed to leave the NAICS code field blank because we could not definitively identify what type of business New Beginnings operates. I would greatly appreciate your interpretation or any reference materials like a previous FinCEN FAQ or SAR Activity Review Trends, Tips & Issues that would clarify or address this issue.
Is there ever a time when an SSI account is over $2000?