Did You Know That?

It's interesting to note that no matter how many times you read a regulation, nor how much you take apart the sentences and paragraphs, something always manages to sneak by. We caught up with one of these little quirks last month while attending the International Money Laundering Conference in Miami in May, sponsored by MONEY LAUNDERING ALERT, the MIAMI REVIEW and the law firm of Fine Jacobson Schwartz Nash & Block.

Richard A. Small, Special Counsel, Division of Banking, Supervision and Regulation of the Federal Reserve Board of Governors was on a panel when someone asked him a question about the effectiveness of the $3000 logs that must be maintained by financial institutions for the sale of official checks, treasurer's and cashier's checks and money orders.

We've noted in the BANKERS' HOTLINE in previous issues the frustration of this added chore in the banking offices.

Rich's response, later confirmed by Peter DiJinis, Director of the Treasury Department's Office of Financial Enforcement, was important enough for us to quote him directly.

Rich said, "If a financial institution has, in its policies and procedures, that it does not accept cash from non-customers to buy negotiable instruments-and requires customers to deposit cash and buy negotiable instruments with a check-and does not deviate from those policies and procedures-the financial institution does not have to maintain a log."

Peter DiJinis concurred with Richard Small's statement, adding, "It is not universally known that you do not have to keep a log under these circumstances."

You may want to take a look at your policies and procedures and make some adjustments!

Copyright © 1993 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 4, No. 1, 6/93