Bank Employee Delivered $10k in Cash (BSA/CTR)
01/13/2019
A bank employee (not our courier) delivered over $10k in cash to a bank customer. Do we have to identify the bank employee personally or can we say Armored Car (FI)?
Ken Golliher is a principal with Pegasus Educational Services, LLC., a training firm organized in 1996 with headquarters in Louisville, Kentucky. Pegasus specializes in technical and regulatory instruction for financial institution personnel. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection school for examiners. Ken has also been an instructor at compliance schools sponsored by the Illinois, Georgia, Indiana and Nebraska bankers associations.
01/13/2019
A bank employee (not our courier) delivered over $10k in cash to a bank customer. Do we have to identify the bank employee personally or can we say Armored Car (FI)?
01/06/2019
An authorized signer wants to be removed from an account. If the account owner will not remove the authorized signer, what options does the authorized signer have?
12/30/2018
We have a business that pays their employees by checks drawn off the same account. The employees sign the checks and gives them to the same person to cash the checks for them. The total of all the checks is >$10,000. The person bringing the checks into the bank to cash them, signs under the employee's name on all the checks. How should the CTR be completed? Is she the conductor for all the employees or is it on her own behalf?
12/16/2018
If a foreign customer's W-8 expired and their individual account is not interest bearing; do you still need to place them on backup withholding?
12/09/2018
We got a request to open an account for an Honorary Consulate in US, WA state. I did look online for WA state list of licenses and could not find any related information. Could you please help me with a required documentation?
12/09/2018
Can someone please tell me whether, for an IRA customer over 70 1/2 who has an RMD, does the federal tax withheld get deducted from the RMD amount or is it an additional % on top of the set RMD amount?
12/02/2018
Can I restrict an account up to 60 days for investigation purposes when depository account experiences return items that return as fraudulent or unauthorized? Also can the 60-day restriction be extended after each returning deposit? When do I start counting the 60 days? When the last return item is received? EX: receive 1st return item on 10/1- 60 days is 11/29, receive 2nd return item on 10/3 can I extend the restriction until 12/1, so on and so on?
11/25/2018
I have a new customer who has a single member entity that is disregarded for tax purposes (rental income and expenses are reported on personal tax return), but has been assigned an EIN separate from his SSN. The entity is 12 years old and he has misplaced his letter from the IRS verifying the LLC's EIN. What is the easiest way to document this to comply with CIP procedures? Can I take his and his accountant's word that the EIN is correct?
11/25/2018
Do we as a bank have the right to refuse a wire transfer request if we feel it is suspicious and unusual activity for a particular customer? This customer had a wire come in yesterday and is now requesting an international wire transfer to Nigeria. Of course we know our responsibilities under BSA and the steps we need to take for suspicious activity, but we also would rather simply refuse to conduct the transaction altogether.
11/25/2018
What gauge of steel is recommended for the under counter of the teller line?