When it comes to BSA Compliance - If a member/customer withdraws $10K each day for 3 consecutive days, in what circumstance would one not think this is a reportable suspicious activity?
We have a new customer, just moved to our town, from an HIDTA county in Florida. When I process a risk aassessment, and use his Florida driver's license address, the risk is a high risk. How long should I monitor this account? He did get a Louisiana license on the day that he opened his account.
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?
Our bank is basically taking the position that we will not provide services to marijuana related businesses. We need to add this verbiage to our policy but I am unsure of the best approach. My thoughts are..
*We will not provide banking services to marijuana related businesses. (straight forward)
*We will not provide banking services to entities or individuals who activity is not considered legal at the state and federal level. (not segregating a specific business)
*After conducting a risk assessment we have determined that we will not provide banking services to marijuana related businesses.
Any insight you may have is appreciated.
I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
Is it possible to money launder in the hotel industry?
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?
Is the Currency Transaction Report 104 a part of the Anti Money Laundering documents that needs to be signed by an Attorney?
This section of the SAR Activity Review provides information related to potential terrorist financing activity. This information has been obtained from a variety of sources, including:
In an innovative use of money laundering statutes, a State successfully prosecuted a defendant for violations of the Federal Bank Secrecy Act.