01/07/2024
Can we re-disclose information from beneficial ownership secure system?
01/07/2024
What are the next steps for beneficial ownership?
12/31/2023
When can a financial institution request information from FinCEN?
12/31/2023
What are examples of types of transactions financial institutions cannot use beneficial ownership rule?
11/12/2023
Would a CTR be required if several individual employees endorsed their respective payroll checks (all individual payroll checks are under $10,000 but combined they aggregate to an amount that exceeds $10,000), and the owner of the business (which is exempt phase 2) cashed them for the purpose of distributing the proceeds back to the individual employees?
Is this allowed under an exemption?
PS - Our Compliance BSA Officer abruptly left the bank with no guidance, and we are trying to make sure we do things correctly.
09/17/2023
Customer A and Customer B (a married couple) open two single-owner CDs with cash. Customer A's CD is opened with a CTR-reportable amount of cash. Customer B's CD is opened with $5,000 cash. Would Customer B, Customer B's CD, and the cash used to open Customer B's CD be included in the CTR?
07/23/2023
We were notified that we have a duplicate CTR filed. However, it does not meet the requirements to be considered a duplicate by FinCEN because it has errors and does not exactly match the original.
How do we have the duplicate CTR suppressed or removed?
07/23/2023
We have a non-banking client who received several checks from his deceased grandmother (our client) which total over $10K. He is traveling from KS to Fla to cash these checks. Our problem is that he doesn't have a Social Security Number. Can or should we cash the checks and create a CTR, or refuse him? He does have a DL. He lives off the grid....we will file a SAR for sure.
05/28/2023
A client makes a cash in deposit of $8K. She also does a currency exchange for $5K. We now have a cash in for a total of $13K and a cash out for $5K. Is the $13K reportable since $5k is an even swap? I believe it is but I just need clarification.
05/21/2023
We've classified a 501(c) nonprofit organization as a phase I government entity because it receives public funds. We have not filed any CTRs because of this. We've had questions about it, does this not qualify as a government entity as stated in 31 CFR 1020.315?