Inquiries Received by FinCEN?s Regulatory Helpline By FinCEN?s Office of Outreach Resources
Are banks required to check the entities listed in section 311 of the USA Patriot Act every time an international wire is sent or received, and is this part of the FFIEC Examination Manual?
The FFIEC BSA/AML Manual dated 8/24/07 states that "the exemption of a Phase I entity covers all transactions in currency with the exempted entity, not only transactions in currency conducted through an account." Phase II's are exempt with respect to transactions conducted through its exemptible accounts. From this, can we conclude that a straight $12,000 currency exchange by an exempt bank would be an exemptible transaction but that a $12,000 currency exchange by an exempt "non-listed business" would not be exempt from reporting?
Firms are required to file SARs that are complete, thorough, and timely.
Does BSA/AML risk assessment have to be approved by the board?
We have been offering remote deposit capture for nearly two years. The FFIEC guidance issued in January, 2009 says institutions should do a risk assessment first. We didn't. Is it too late?
John Burnett, BOL Associate Editor
Do regulations require a specific pandemic flu "Policy". We are incorporating procedures for avian flu/pandemic in our disaster recovery plan. Is this sufficient?
Date of ?Initial Detection? and the 30-Day SAR Clock By FinCEN Office of Outreach Resources
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?