Is it possible to money launder in the hotel industry?
By FinCEN Office of Regulatory Policy
Relative to BSA/AML, is there anything within FFIEC guidelines, or anything else for that matter, that states a bank must get the purpose for a wire/funds transfer? At a previous institution that I worked at we were cited by the OTS because we were not obtaining the purpose for a wire transfer. I have spoken to other colleagues and they, too have been cited; however, no one can find where this is an actual BSA requirement.
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?
Any guidance on completing a worksheet for enhanced monitoring of correspondent banks would be appreciated. Specifically risk factors to watch...what would be the most critical? How can correspondents be monitored in a timely fashion when call reports come out quarterly?
As a community bank, we do not open accounts for MSBs due to the risk. However, we have several businesses that are agents of MSBs such as Sigue Corp, RIA Financial, Moneygram, and Western Union. Is the MSB responsible to see that these businesses are meeting reporting requirements, or are we to enhance our due diligence in overseeing these accounts?
What does it cost to have a cyber security firm test a bank's computer security to find out where the bank is vulnerable to outside hackers? Who does this work?
I have been trying to research products to replace an in-house solution for managing investigative cases. Is there a fair place where products such as these are reviewed and users can give feedback on them, similar to what Amazon.com does for products it sells?
I have been in banking for awhile and am being told I am making a mountain out of a mole hill. When it comes to DBA accounts, I have one opinion on what purpose/style account should be opened and I am being told by others that I am not correct. There are two differing opinions when we open a DBA account. For example, one opinion is that Mickey Mouse DBA Great Escape Mousetraps should be opened as a personal style account, where at the account maintenance level, the code would indicate consumer for the purpose of household or personal use. The other opinion is one in which it should opened as a business style account, where at the account maintenance level, the code would indicate business for the purpose of business. The reporting tax ID number in both situations would be the customer’s Social Security Number. If I understand correctly, there are different regulations regarding the purpose/style of an account and there are different protections and benefits for each purpose/style. Can you please help as to which purpose/style would be proper? My best interest is doing things the correct way for the both the bank and the customer.
I've been in banking for many years and cannot recall ever having a church on the exempt list for CTR filing. I have a branch requesting that their local church be considered. I am unable to find anything in the FFIEC Manual stating specifically that we cannot, but for some reason I don't feel right about it. Are you able to provide me some guidance?