In the past, secretary of state information is not always reliable and easily changed. How can we rely on those public websites?
What is the “one-click away” rule for electronic advertisements?
How much notice must be provided before this service is eliminated?
Are nonprofits included in beneficial ownership certification? What about shared EINs?
Before we eliminate this service, are there any other ways to provide it?
Our institution is based in Missouri, but we offer an online savings account. We are wondering about what state laws we use for charging dormant/inactive fees to accounts? Missouri Law is that once an account is inactive/dormant for twelve months we can charge a fee up to $5.00 a month. Then after five years of inactivity, the account is considered abandoned and will need to be sent to the State Unclaimed Property department. If a customer from different states opens accounts online with us, do we abide by Missouri Law or the state law which they reside in?
We are not yet partnered with Zelle. If a customer uses the app to transfer funds and the funds do not reach the receiving end, is it a Reg E matter?
We are trying to determine whether or not a customer qualifies as a dealer of precious metal, precious stones or jewels and if so, what is required with regard to AML and OFAC.
The customer sells jewelry on Etsy to the general public including rings, earrings and necklaces. Most of the rings come with a gemstone. The metal of the ring is made with sterling silver, 10K gold and 14k gold. Gemstones include aquamarine, cubic zirconia, alexandrite, lab (man-made) sapphire, lab created ruby, lab created emerald, amethyst, moonstone, blue topaz, garnet, quartz, period and morganite.
The customer purchases approximately $150,000 from foreign vendors in Hong Kong.
- Does this customer qualify as a dealer in precious metals, stones and jewels?
- And if the customer does qualify, what documentation does the customer need to have in place with regard to an AML program, OFAC, risk assessment, etc.?
- How are dealers in precious metals, gemstones and jewels advised that they are required to have this documentation?
- Are they regulated, and if so by who?
Any insight you could provide would be greatly appreciated.
Are trusts included in beneficial ownership?
We closed our investigation when we received credit from VISA after filing our charge back. Later the merchant provided information showing that our customer performed the transaction and took the money back. Can we debit the customer’s account?