We are a small community bank with $250 million in assets. We have lost our compliance officer again. Unfortunately, we can't justify a full time position for this. Do you know if banks are outsourcing this function and if so, where do I look to find the firms who offer this service?
Is there a required list of questions we should ask at account opening?
Is it possible to money launder in the hotel industry?
I have been monitoring & submitting a SAR on a business for a couple years. In retrospect, this customer has been consistent in the activity that no longer looks suspicious, so I don't want to close the account, but I don't think a SARs is needed to be submitted anymore. What is the requirements or protocol to change the status of the account from suspicious to maybe just unusual or even low risk? Can I just stop filing a SARs and make notation on the existing paperwork that SARs are no longer needed due to consistent activity that doesn't flag the account as suspicious anymore?
When we open a new account we generally ask the customer whether he/she is a U.S. citizen or not. Once we find out that they are not a U.S. citizen, how far do we have to go in determining their immigration status concerning legal alien/illegal alien/legal worker/illegal worker? For example: If the person is applying for a business account and from immigration documentation we see that they are currently not allowed to work, what is our responsibility?
Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
Are there any compliance regulations that require a bank to request and document the purpose of wire activity?
We are completing our annual due diligence review of customers exempt from CTR filing requirements and have discovered a customer who no longer meets all the criteria for exemption. Are we required to obtain a back filing determination for their activity in the preceding year?
Does anyone have a form they use when opening a business account stating they are not an MSB?
We are trying to determine who should complete vendor due diligence, the department manager wanting a new vendor or the bank's risk department?