Most Popular Compliance Content
Frequency of High-Risk Reviews
03/26/2023
How often do we need to review our high-risk customers?
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.
Fraudulent Check Requirements
03/26/2023
We are a bank located in NY. We would like to know if it is required under state (if you know) or federal laws to have a customer sigh a claim form for an unauthorized/forged/altered check? If so, is it required to be notarized? We are aware that NACHA made provisions during the pandemic to allow WSUDs to be taken verbally, however we would like to know if it's necessary for checks and specifically if a Notary is needed as one might not be available in the branch on the day the claim is made.
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.
How can automation improve my sanctions screening and management processes?
03/26/2023
How can automation improve my sanctions screening and management processes?