OFAC Check - Non-customer Transactions

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Question:

I need an opinion. This is about servicing non-customers and aggregating for BSA. We cash on-us checks for non-customers. We also sell money orders to non-customers. Our front end teller system completes an OFAC check prior to completing the transaction and our core database software reports and aggregates all cash transactions by SSN for BSA reporting and for AML tracking. Our new senior management has overridden my opinion that we should always collect a SSN on these non-customer transactions. What they are going to implement is a threshold value for these transactions. No social will be required for non-customer transactions under a certain dollar amount. The OFAC check will still be performed on the non-customer name. I feel that now we will be giving preferential treatment to non-customers where we will be tracking all cash activity on our customers.

Answer:

I am going to side with management in this case. The key difference is that your deposit customers are required by law and regulation to provide their Social Security numbers (or other identifying number if not U.S. persons); non-customers are not required to provide it unless they are conducting a cash purchase of a monetary instrument that triggers the $3,000 recordkeeping requirement, or have to be listed on a CTR. Does this make it more difficult to complete a CTR if a second or third visit on a given day would, aggregated with earlier cash transactions, trigger a filing? Yes, unless your system can aggregate by name and can alert a teller at the time the trigger point is reached.

First published on BankersOnline.com 8/10/09