How can I communicate IT risk in terms that the business can understand and use to make immediate, measurable cost versus benefit risk decisions ?
I need to amend our BSA policy in order to address the new rules for FinCEN CTR exemption reporting. How do I go about doing this?
A big part of our IT Security budget is spent on GLBA compliance. Are we doing something wrong?
An examiner (FDIC) found that we should have a formal referral system for reporting what is suspected to be suspicious activity to me, the BSA Officer. She suggested that I create a form available to all employees to be completed by any employee who sees what he or she considers suspicious activity. Does such a form exist and if so, where can I find it? If not, what information would you think I need to include in the form?
What do regulators want us to check for to satisfy stress testing requirements?
A customer presents a teller $12,000 in cash to purchase a cashier’s check for $11,600 and receives $400 back in change. When completing the CTR should the amount initially received from the customer or the amount of the transaction be used? Where would this answer be found in the Regs?
How long do we have to keep the information collected from the monetary instrument logs and where would I find the citation?
Is CIP documentation required for court ordered accounts such as when minor children receive money from a sale of property and the court orders CDs to be purchased for the minors and held until they are 18 years old?
I have some questions relating to penalties and prison terms for violations. What is the maximum fine and maximum prison sentence for willful BSA violation? What is the maximum fine and maximum prison sentence for violating anti-money laundering statutes? What is the fine for negligent CTR reporting and the fine for willful violation of CTR reporting? I have looked on FinCEN, checked the IRS and your website for a definitive answer and can not seem to find one.
We have a customer who deposits small amounts of cash at different times that total over $10,000. What is the time period to collect this information? We are worried this might be money laundering and/or structuring.