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Lining Up FACT Act Players

06/01/2004

The FACT Act requirements are rolling into place. By this time next year, everything will be final.

Timing Triggers for SARs

03/01/2004

This question is about BSA/Anti Money Laundering Operations. We have some conflicting points of view at our bank regarding when the clock starts (for 30 filing deadline) on SAR filings. Some staff are under the impression that we must file a SAR within 30 days of suspicious activity, whereas other staff believe the filing must occur within 30 days of when we determine that the activity appears suspicious. Which is it? We try to detect all suspicious activity through automated reports and research each month.

Timing Triggers for SARs

03/01/2004

This question is about BSA/Anti Money Laundering Operations. We have some conflicting points of view at our bank regarding when the clock starts (for 30 filing deadline) on SAR filings. Some staff are under the impression that we must file a SAR within 30 days of suspicious activity, whereas other staff believe the filing must occur within 30 days of when we determine that the activity appears suspicious. Which is it? We try to detect all suspicious activity through automated reports and research each month.

Where Should a Newbie Compliance Officer Start?

12/01/2003

I have just been nominated compliance officer of a thrift at which I am a new employee (this is my 3rd week). I have 15 years previous banking experience in almost every department but never in compliance. Where should I start?

BSA Examinations

11/01/2003

The agencies are in the process of publishing new examination procedures for the new components of anti-money laundering programs generated by the USA PATRIOT Act.

Learning from Enforcement Actions

09/01/2003

Commonly cited violations have long been a source of important information for the design and management of compliance programs.

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Returned Check Rules

03/26/2023

I would appreciate direction on where to find in the regulation(s) the requirement for counterfeit checks to be returned within a 24 hour period of payment. We have a client that has had a counterfeit check clear their account and needs proof that it must be returned the next day or it is considered a late return.

Handling Deposits of MRB Staff

03/26/2023

A dispensary (Marijuana Related Business) just opened this month in town. We have two members (we are a credit union) that receive payroll from there (ACH). - Given their employer, is it illegal for them to bank with us? - Do we need to terminate our relationship with them? Our policy only states for MRB's that we would allow tier 2 and 3. Technically it is an individual, not a business though. Are we allowed to keep them? I know there are SARs we may have to file for MRB's (limited/terminated, etc.). If we keep thee depositors, do we have to file a SAR every 90 days on the individuals as long as they are employed at the dispensary? We understand there is a certain risk having them. There is really no guidance from FinCEN regarding employees of MRB's, just MRB's themselves. Any guidance would be greatly appreciated.

Reg E is “use dependent”

03/19/2023

I have heard that business accounts do not fall under Reg E. How does this apply to internet banking and what about a business account that is a sole proprietorship?

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