Can we re-disclose information from beneficial ownership secure system?
What are the next steps for beneficial ownership?
When can a financial institution request information from FinCEN?
What are examples of types of transactions financial institutions cannot use beneficial ownership rule?
I am in the process of exempting a business as a Phase II Customer. It is a local grocery store that is a registered MSB (due to cashing checks over $1,000). Can an MSB be exempt under Phase II? I have been told by an examiner that yes they can, but then I have been told by a rep from FinCEN that no they can not. Also, if they can be exempt, what forms besides the BSA Exemption Review Form do I need to obtain? We only have one other Phase II Exemption who also provided their P&L's. This business, however, is not willing to provide this information. I have weighed out if it would just be easier to go ahead and continue filing CTR'son this business, but with at least 4 CTR's per week, it would be better to exempt.
A customer asked me what to do with $13,000 in cash. What is the conversation I should have with the customer?
What is the timeframe for filing the FinCEN CTR? I have seen both 15 and 25 days referenced.
I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?
When the owner of an ATM resides in a state that requires the ATM be registered refuses to register that ATM; do you file a SAR on that customer for failure to provide documentation? If a SAR is required, does the continuous SAR filing rule apply until the customer complies?
My question is, for an outgoing wire does it need to have a physical address or can it be processed with a P.O Box address?