Under the USA PATRIOT Act regulations and upcoming CIP, do we need to have photocopies of the driver's license and/or social security numbers for beneficiaries on a Totten Trust? In most cases, we never see the beneficiaries, as they are not signers on the account. Also, do we have to check them on OFAC?
I'm looking for a list of countries, beyond those on the OFAC list, that would fit the definition of "tax haven" or other countries that should be monitored for suspicious wire transfer activity.
What security/liability concerns should a bank have when an employee has a spouse/friend/associate on the terrorist watch list?
Does a SAR need to be filed every time a financial institution has a hit on the OFAC List? If so, what should be listed as the type of suspicious activity?
Do you know of any companies that may offer software to banks ( to purchase) which has the OFAC listings and updates?