08/24/2009
When it comes to SAR filing, who should make the final decision to file? The President, Board of Directors or the BSA officer?
08/17/2009
Do tellers need to run an OFAC check on a non-customer that comes in to cash a check on a customer’s account? The checks range anywhere from $5.00 to over $2500.00.
08/10/2009
I need an opinion. This is about servicing non-customers and aggregating for BSA. We cash on-us checks for non-customers. We also sell money orders to non-customers. Our front end teller system completes an OFAC check prior to completing the transaction and our core database software reports and aggregates all cash transactions by SSN for BSA reporting and for AML tracking. Our new senior management has overridden my opinion that we should always collect a SSN on these non-customer transactions. What they are going to implement is a threshold value for these transactions. No social will be required for non-customer transactions under a certain dollar amount. The OFAC check will still be performed on the non-customer name. I feel that now we will be giving preferential treatment to non-customers where we will be tracking all cash activity on our customers.
08/03/2009
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.
06/15/2009
06/01/2009
We are putting together our BSA training schedule. What courses are required annually and what can be done every other year or on an alternative schedule?
05/25/2009
Which supplier failures could cause significant impact to bank operations?
05/25/2009
How can the bank cut cost in risk and compliance management for third parties?
05/18/2009
How can the bank optimize its vendor risk management efforts?
05/11/2009
We are trying to find specific regulations on training requirements for security officers. Is this spelled on in the regs? Does anyone have a list of security officer training recommendations?