Is a Mexico drivers license a valid ID for CTR purposes and if so, would this be a line 14(d) item? The normal IDs one would expect, matricular or nonresident alien work card, are not available in this case.
We currently have an unwritten procedure that when a customer moves here from another state, we obtain the driver's license info from the state where they used to live, then when they get a new driver's license from our state, we update our info on our computer system. Management doesn't want to obtain any new driver's license information unless the out of state driver's license has expired. They now deem it to be too much trouble.Our CTR software pulls info from the computer system and thus will use the out of state driver's license until it expires. Is this going to cause trouble somewhere down the line? If law enforcement needs to investigate, the only record we'll have is the out of state ID.
We have a customer born in the US, with a SSN and State ID. He wants to have a debit card with his name in Spanish, as he may travel to Mexico. Are we obligated to do this? Would this violate CIP and BSA requirements?
We have several attorneys who maintain IOLTA accounts with our bank. They all use the same tax ID and their transactions aggregate on the large cash transaction report. If they are acting independently, would we still need to aggregate the transactions for CTR reporting?
The size of banks BSA Programs has increased to 50 pages or more. I would like to strip the BSA Policies/Program of specific procedures. The BSA Program would refer to a procedures manual with appropriate ID. This way, anytime procedures needed to respond to changes they would not need board approval. The question is: can I have a separate BSA/Policies/Program, which references a separate procedures manual?
Can someone please explain what “push” and “pull” mean in regards to e-banking?
We have a situation where an ex-spouse has been accessing the online banking portal of one of our customers. This ex-spouse has not transacted anything fraudulently as of yet. We have reset the password since being notified of this unauthorized access. We have verified, via IP addresses and times, that our customer did not log in and that it was in fact, the ex-spouse. What law(s) have been broken by the ex-spouse logging into the online banking site of the customer? Are there any areas of Reg E that would apply?
Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?
Are government agents or law enforcement employees exempt from providing their personal information for CIP when they open accounts?