The new Beneficial Ownership rule adds the CDD Fifth Pillar to the AML program requirements for (a) developing a customer risk profile, (b) conducting ongoing monitoring for reporting suspicious transactions and, (c) updating customer information. What CIP procedures should we follow when a business client provides online banking access for an employee who has the authority to initiate transfers or make bill payments?
DDA customer account auto closes because the balance went to zero. Customer comes in 2 days later wondering what has happened. Must they be re-CIPed to re-open their account?
I have a customer who is opening an account for her husband to receive his Social Security disability payments and she is the representative payee. Is there a certain way that should labeled on the signatory card and shouldn't her husband's SSN be used?
When submitting a CTR for a business with a corporate address and a site-specific address, which one do we use?
The husband of a long time customer of the bank, is using her account to deposit large dollars in postal money orders, cash, his social security check and wires for services he provides. The money is then Paypal'd out. We have no idea of the source of these funds. Her paycheck is an ACH not in questions. We have been filing SAR's for a year. Should we leave the account open?
What are the proper procedures to CIP for an attorney-in-fact (AIF) under a power of attorney? My question comes from an instance where we have a CIP grandfathered Amish customer and they would like to add someone to their account that doesn't have a TIN and refuses to get one. They went to an attorney to get around the CIP restriction and made him an AIF so he wouldn't have to go through the normal CIP process. Is an AIF considered a customer under 103.121?
When we have a non-profit organization our bank titles it like "Jane Doe D/B/A as Girl Scouts Troop 55" and uses Jane's Social Security number. Where I worked at before titled accounts in the form "Girl Scout Troop 55" and used their own tax number. Can accounts be styled two different ways?
Recently, our New Accounts has opened a few Guardianship Accounts. They have the proper documentation but we believe that the accounts may be under the incorrect social security number. What social security number should the account be filed under? Is it the Guardian (representative) or the Guardianship (beneficiary)?
We have a new business customer who is opening an account with two signers. One is a local person, the other is abroad permanently. What would be the proper way to conduct CIP on a person abroad?
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?