If we do an OFAC check on our accounts (past 12 months) and there is one account hit, should we send the account name to OFAC? Do we need to find out the transaction of the account?
We currently use armored carrier services for our MSB customers when ordering cash. For CTR reporting, we report on "delivery date" Vs "order date". Going forward, we are conducting research and looking to report our CTRs on "pick and pack", which is the date funds are actually removed from our vault, but not delivered to the customer. Would this change be acceptable to the IRS?
For purposes of setting up an estate account, who is considered the customer for purposes of CIP?
Regarding foreign ATM deposits of more than $10,000, we have no way to identify if they were made by cash or check. Is there any responsibility for BSA reporting in these instances?
If a customer had someone make counterfeit checks with his account number on them and then that unauthorized person used these checks to purchase items from a store that processed the check electronically, what are the time frames for customer reporting and the bank returning the item as well as required paperwork? It appears we are crossing from checks to Reg E and I am not sure what applies where.
Would there be a fine to a financial institution for not filing a SAR on an employee for check kiting?
Our bank has a local utility company that has regularly been making CTR reportable deposits from cash payments for utility services they provide. If our bank decides to exempt them from CTR reporting, we feel they would be considered as a Phase II Exemption. However, since they are a public utility (although local) could they instead be considered Phase I (government entity) instead? We want to make sure to document this properly if we decide to exempt the company.
I was told that a customer should not be informed of being exempt from Currency Transaction Reporting. Is this correct? If so, why not?
We have a customer who has documentation to support that he is a non-resident alien, however he meets the substantial presence test and has a "For work purpose only" social security card. Would this customer be considered a resident or non-resident alien for bank purposes, and can we use the social security card for CIP documentation?
Can a partnership report under one of the partner’s social security number, rather than filing for a EIN?