The new FFIEC BSA/AML Examination manual is out! The agencies published it today, June 30, 2005.
If a grocery or convenience store states, in writing, that they will no longer cash checks (for free) of $1,000 or more, must they register as an MSB? Is it, once an MSB, always an MSB?
Is there any legal or regulatory reason stating we need to record ID on the face of a check when cashing checks? We would like to record the ID on the supporting document for privacy reasons.
Recently, we discovered check fraud on a customer's checking account, who has since passed away. The signature on several checks does not match that on the signature card. Since the customer is deceased and the beneficiary on the account has taken ownership, should we expect any repercussions as a result?
If bankers have a policy not to ID existing customers: <ol><li>How then are they satisfying CIP? <li>Are they assuming the risk? <li>Or is there some other way to handle this? <ol>We were assuming the risk and made an assumption that we had previously identified our existing customers before the regulation was passed. With stepped up compliance, we are no longer comfortable accepting this risk, but cannot think of any other alternative than to ID our existing customers. We cannot seem to identify any workable alternatives. Do you have any suggestions