The purpose of this Section is to provide financial institutions with information relative to various aspects of terrorist financing to assist them in identifying and reporting related suspicious a
In an effort to eliminate duplicative reporting, on December 23, 2004, FinCEN published a final rule updating previous guidance on filing Suspicious Activity Reports involving individuals or entiti
Has OFAC discontinued the e-mail notifications of changes to the SDN list? I have not receive one in the last two or three months.
After a recent exam, our institution had an informal recommendation to address procedures for addressing gov't requests for information (separate from OFAC and 314a) in our CIP Program. Any help on what is this informal recommendation should include?
I am looking for guidance on what to tell the customer standing in front of a customer service individual when a positive hit comes back on the OFAC list to insure the employee's safety as well as the integrity of our bank.
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?