07/12/2010
According to the Patriot Act, "Know your Customer", when closing a loan for a new home purchase, do we verify the borrower's current address or the one he is purchasing?
01/18/2010
We have some customers that present us what is called the United Nations passport as form of identification. On their applications they state their nationality. For a while, we have considered that ID as valid, but now we are having second thoughts. Would you accept that form of ID? I understand it is not issued by the government, but it has a picture, signature and expiration date and is accepted for crossing borders.
10/12/2009
If a bank relies on an automated ID verification system for both CIP and red flags compliance and there are red flags associated with the name, date of birth, or social security number that go unresolved, are these CIP violations as well as violations of the bank's identity theft program? We only use the system to verify the identity of customer’s who are new to the bank.
05/18/2009
How to Implement Risk-Based OFAC Monitoring Practices
Five steps to risk assessment; ten practices for monitoring
by Timothy R. White, CAMS
02/09/2009
With people getting married and divorced I perform a lot of name changes. With the new red flag compliance regulations, what documentation is needed for a name change? In the past we generally just asked to see a license with the new name on it. Is a divorce decree or a marriage certificate the proper documentation?
12/08/2008
Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?
11/17/2008
I'm not sure if we have crossed any compliance or legal lines by allowing the following with regards to online banking access. A customer is both an officer and an authorized signer on a business account, either a corporation or LLC. This person also has a personal DDA account with the bank. The customer has applied for and been granted access to view his business account via our online banking product. The same customer also wants to view his personal account via online banking, but he does not want to have a separate access ID and password for the personal account. To honor the customer's request we have granted viewing privileges to both the business and personal DDA accounts under one access ID and password. Can you tell me if we have entered a gray area by doing this? Should the bank insist on keeping business and personal accounts separate in online banking by having different access IDs for both types of accounts?
10/27/2008
08/11/2008
Does a customer need to sign the US Patriot Act form?
08/04/2008
Should we accept the government issued "smart card" as ID for opening a new account?