09/01/2024
We have a commercial customer that cashes checks, but they are not registered as an MSB because they have a policy to not cash checks for one person over $1000 in one day. We found one instance of checks cashed over $1,000 for one person. Are we required to have the customer register as an MSB, or can we verify their check cashing policy and continue to monitor the
account for any further instances?
08/11/2024
Our BSA Officer manages our bank’s filing of Suspicious Activity Reports (SARs) with FinCEN. She has asked to include in our policy for managing summonses, subpoenas and similar legal documents a requirement that she be notified of any suspect activity that might be turned up in searches in response to those documents. Is that allowed?
04/14/2024
If using a software program, we become aware of a check drawn on our customers account is for sale on Telegram (a marketplace for help depositing a stolen checks) and it is over $25k would a SAR be required? We froze the item and to our knowledge the check was not purchased or negotiated.
01/21/2024
I have a CTR question I have yet to see posted anywhere. Any cash
transaction(s) more than 10K to a joint account by any conductor is a CTR. However, what if there are multiple (3) joint accounts. EX: $5,000 cash deposit by Suzy to account A; $5,000 cash deposit by Suzy to account B; $1,000 cash deposit by John Doe to account C. All 3 accounts are jointly held by the conductors. Would this be considered a CTR because Suzy and John can benefit from the $11K, via separate accounts or exempt because not more than one person conducted to a single (one) joint account?
09/17/2023
I am looking for guidance on what information to include on subsequent filings of a Marijuana Limited SAR. I followed the guidelines on Fin-2014-G001 for the initial SAR - and now have a 90 day coming due. I'm looking for any suggestions or documentation?
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.
03/19/2023
When filing SARs, for the total amount of reported activity would you include both incoming and outgoing transactions when it's the same funds?
Example: Customer received an unusual wire for $50,000 and withdrew the funds in a structured manner. Would the total amount reported be $50,000 or $100,000?
10/09/2022
Am I encouraging a customer to structure if I make them run cash as a deposit into their account ,and then debit their account for a cashiers check instead of letting them just purchase a cashiers check with cash?
I like to have a paper trail and proof that the purchaser is a customer, that is why I run it through an account first.
03/20/2022
If we have a FinCEN 314(a) match, besides reporting it on the SISS website,must we file a SAR?
01/09/2022
If a cash intensive business has a private ATM which they service themselves and they do not have any cash withdrawals from their account, would that in itself be SAR worthy?