04/08/2013
We have a main office and five branches. We have always used our main office address for CTR filings (and recently the RSSD for the main office). I became aware today that each branch has its own RSSD number (thanks to your BOL Daily Briefing)Should we start using the individual branch address and unique RSSD number, based on where the transaction took place for CTR filing? What if it has multiple transactions and multiple locations?
08/16/2010
What laws impact the ability to carry a weapon in a bank?
06/28/2010
I am trying to find some help in revising our security policy, and was looking for a sample policy. Any suggestions?
12/31/2008
When should pandemic supplies be purchased?
12/22/2008
Do you recommend the hiring of a consultant for the creation of a pandemic policy?
08/11/2008
Are there any restrictions or regulations on transporting cash between branches using a bank courier service?
04/28/2008
Is there a standard on all clear questions throughout institutions? Should there be one question used bank wide?
03/31/2008
Is there a standard on all clear questions throughout institutions? Should there be one question used bank wide?
01/21/2008
Do you file a CTR if two individual's cash out two checks payable to the same entity and the amounts of the checks are both for $9000, which when combined totals $18,000.00? The two conductors went to different branches of the same bank as well.
06/04/2007
One of our branches has a customer (a builder) writing large checks to their employees on a weekly basis ($5k-$7k). The builder comes in with the employee to cash the check. The employee endorses first, then the builder endorses and cashes the check. The builder is a known customer, so the tellers do not get identification on him and since he endorses after the payee they are not getting the payee's identification. They are, however, checking the payee/employee against OFAC. Bank policy states that we check OFAC on all non-customer payees over $1000 and record identification on non-customers and payees over $3000. I am getting a match on two of the three employees. I am 90% sure that it is a false positive, but I cannot confirm or deny it is a valid hit unless I can compare their identification information to the hit. The branches administrator was notified that the branch is not following bank policy and that identification needs to be obtained on the payees. The branch defends their actions stating that, technically, they are not making an exception since the employee and builder are presenting on-us checks we are able to verify funds and also that the last endorser is vouching for the non-customer. I understand their concern because it is technically true, but as the Compliance Officer I also understand that, per OFAC, banks must block transactions that are by or on behalf of a blocked individual or entity. If this branch continues to willfully ignore the intent of the customer, which is to give money to this employee, we will end up with severe penalties if the payee is found to be a blocked individual. This is a risk I would rather the bank not take. Can you shed some light on the subject?