05/06/2018
If Bank receives a copy of a DL for a Beneficial Owner that has a different address than supplied on the collection form or the Bank is only provided a passport with no address, would we need to collect other documents to prove address and/or social? I feel like we would be criticized for only being able to verify two out of four pieces of identification.
04/22/2018
With the new expectations of the CDD Rule that goes into effect next month, are we required to identify authorized signers on business and organization accounts?
02/04/2018
Can a financial institution run Chexsystems on a business? Or do we run Chexsystems on all beneficial owners and signers upon written consent?
10/29/2017
What compliance risk is there associated with one of our business deposit account customers asking us to cash checks for their employees? The employees do NOT bank with us AND the payroll account is drawn on an outside
bank.
I am worried about the CDD and the BSA aspects of engaging in this type of activity. Any thoughts?
10/29/2017
When BSA holds an incoming wire because they need more information such as invoices, It is our procedure to send a service message to the originating bank and ask for that required info. Sometimes, we are asked to contact the customer and ask for that information from the customer. Is that against any violations or do you think that could offend the customer in any way? Should a specific dept like BSA, contact the customer for that information to avoid having a dept like customer service, that doesn't have any knowledge on that, say something incorrect?
10/29/2017
How do I start preparing for the new Beneficial Ownership/CDD rules?
10/01/2017
I need to find out the methodology of BSA audit quality control. Is there a check list to ensure my audit firm is doing a good audit job? (basically evaluate the quality of audit, including scope, procedures and work papers).
09/24/2017
With the new CDD Regulations, will we need to verify signers and CIP on participant loans? Also - Is there a specific way to verify the information for CDD with the shareholders of a company?
09/10/2017
Upon identifying specific weaknesses in your AML program that there is not ample time to correct or strengthen prior to an upcoming BSA/AML exam, what action should a BSA Officer take relative to the Board of Directors?
09/03/2017
Your Treasury Management (TM) department’s procedures indicate that clients who repeatedly exceed their daily remote deposit capture (RDC) limits are reviewed and reported/referred to BSA. Has your BSA department ever received an internal referral from TM regarding exceeded RDC daily limits?