I have been told that the employees in charge of on-line banking are considering allowing wire transfers through our new on-line banking product. What kind of compliance and security issues should they consider when they are designing this product? We are new to on-line banking so my feeling is that we should learn to crawl before we run. Some of the bigger banks do not have this on-line banking feature. How does our midsize bank think they have the resources and the knowledge to accomplish this?
When Bill Fox took over FinCEN (Financial Crimes Enforcement Network) in 2003, he promised to review a controversial policy that had been the cause of considerable consternation to bankers.
We've never had a match on OFAC or FinCen. We've had close ones but never an exact match. What is the record retention requirement for those reports that we've printed and reviewed to check the possible matches?
We are in a rural area and have in the past cashed Tax Refund Checks (IRS or Tax Preparer's) for non customers. We charge a fee and require all payees to be present with valid ID. Under BSA, CIP, AML, OFAC, do we need to stop this practice? If not, do we need to retain the ID information for 5 years and also check the OFAC list?
We open renters' security deposit trust accounts. Do we need to verify the tenant's ID and check his/her name against the OFAC list? I know that for the landlord we have to do this. Is it sufficient to just keep the W-9 on the tenant?
We have a procedure to review unusual activity in employee's accounts on a regular basis. In addition, if we have a suspicion regarding a teller, we have reviewed account activity for that teller. Are there any privacy rules which would restrict our ability to review our employee's account information? Also, is there any consent required by the employee when they begin employment?
Real Estate Industry ? Sales and Management SARS
A verified match with an entity on an OFAC list that involves funds in an amount above the applicable SAR filing threshold should trigger a SAR filing requirement.
General Instructions for Completing the SAR Form
We have software that can be used to run our customer base against not only the OFAC list, but also a more expansive list. The name list that the software contains in addition to the OFAC list, is an FBI list. My question is this, is the bank required, by any law/regulation/statute, to review any matches other than OFAC list matches? The matches we have appear to be simply common name matches, but obviously I don't want to be out of compliance.