How much information can a financial institution share with another financial institution that is under the 314(b)?
In an innovative use of money laundering statutes, a State successfully prosecuted a defendant for violations of the Federal Bank Secrecy Act.
We have an attorney who wants to open an escrow account; however, the funds are from an estate that is being contested. He wants to open the account with the deceased's SSN. Should he not have to get a tax ID number?
I work in the retail division of a bank. A handful of our merchants collect payments in-store, and if a cash payment is made over $10,000, we complete a CTR. Since we are regulated by the OCC, is there a cap on the number of CTRs that can be completed each year?
Inquiries Received by FinCEN?s Regulatory Helpline By FinCEN?s Office of Outreach Resources
By Agents of the Federal Bureau of Investigation and Immigration and Customs Enforcement
We had an ATM robbed and lost more than 25K. I don't think we file a SAR on this, is this correct?
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.
We have a CD with a father as the primary owner and his two children as co-owners. The father passed away. Does the interest get reported to the father’s social security number up until the date of death?
Is a CTR necessary if a husband and wife come in to the Credit Union together and each withdraws $10,000.00 from his/her own account and both are joint on each other’s accounts? Would a CTR need to be filed for the amount of $10,700 on a deposit of $700 to a personal joint account by one of the joint owners and then a deposit of $10,000 made later in the day to an LLP account with same owners (partners) but by the other partner? Later that day, an on-line transfer from the LLP was made to the personal joint account of $9000.