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?
I am in the process of revising our teller procedures to include checking all non-customer transactions against the most current OFAC list. I am still not clear on the non-customer transactions that should be checked. Could you clarify that for me and also, cash and checks both? My understanding is that tellers need to check on the following: all negotiable instruments sold (cashiers checks, money orders, wires, bonds, travelers checks). What about non-customer cashing an on-us check?
We have a case of counterfeit US Postal money orders. Do I have to report that to FBI or Secret Service? If so, how? Do I just call them?
Do we need to CIP and OFAC non-customers if we sell them money orders?
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.
Husband and wife customers came in and purchased $10,000 in savings bonds. They used a $4,000 on us check and a $3,000 savings withdrawal and $3,000 in cash. Our bank completes Monetary Instrument Logs for Official Checks, Travelers Checks, and Cashier’s Checks that are purchased with cash between $3,000-$10,000. Would a Savings Bond qualify as a "Monetary Instrument"?
Use of the Category ?Other?
We are wondering what all constitutes a monetary instrument. Does a CD purchased with over $3000 in cash need to have a transaction log filled out?
Are Savings bonds considered a monetary instrument under the BSA?
Question: We recently started selling money orders for Western Union at all of our branches. We only take cash.