I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?
Are banks required to check the entities listed in section 311 of the USA Patriot Act every time an international wire is sent or received, and is this part of the FFIEC Examination Manual?
Acknowledging the existing CIP (BSA Manual-8/2007) rules, there appears room within the regulations to enroll Amish families into non-interest bearing accounts with an IRS tax waiver (Form 4029) as long as other forms of positive identity are provided such as birth certificate, marriage license, a tax/property deed or baptism papers. I’m looking for verification in this matter.
What is the best way to identify a minor and still comply with the USA PATRIOT Act and CIP? We currently do not accept birth certificates and most times the only ID the minor child has is a social security card. Is that enough?