02/27/2012
Is ACH governed like a wire transfer? What electronic transfers methods are NOT regulated?
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
03/30/2009
Why is it that most banks that originate outgoing wire transfers require a physical address (no PO boxes) for the beneficiary? Is this a compliance requirement and if so, where is it established? I have looked at Reg J, the UCC, the BSA exam manual and the travel rule without much luck. The latter proved more helpful than the others, but still offered little justification for the requiring of the beneficiary's physical address. In this regard, the rule states that the originating bank is only required to retain "beneficiary information provided by the requestor" which may or may not include an address. Any help in determining how and/or why this no "PO box policy" was derived would be greatly appreciated.
09/24/2007
The "Wire Transfers and Reg D" question and response regarding whether or not outgoing wire transfers count in the Reg D limits was first published on 12/1/03. In that response, it was noted "if the request is presented at the bank in person or by customer-hired messenger (or other agent of the customer), it need not be counted under Reg D requirements." For clarification purposes, if an outgoing wire transfer is presented at the bank in person and the beneficiary of the wire is a third party, does the "third party" feature trump the "in person" transaction, making the transfer count in the Reg D limits?
07/23/2007
We disclose that we give same-day availability for cash and wire transfers because the funds are available to the customer if they come into the bank, but they are not available through the debit/ATM card network because we only send a positive balance file after we do our nightly update. Are we out of compliance by disclosing same day availability for these deposits?
12/01/2005
Lisa Arquette, recently appointed to Associate Director, Anti Money Laundering and Financial Crimes at FDIC, shared advice on what to consider in risk assessment at ABA's 2005 Money Laundering Enfo
06/01/2005
FinCEN's 8th SAR Activity Review studied 2,175 SARs reported during that period.
01/17/2005
I have been told that the employees in charge of on-line banking are considering allowing wire transfers through our new on-line banking product. What kind of compliance and security issues should they consider when they are designing this product? We are new to on-line banking so my feeling is that we should learn to crawl before we run. Some of the bigger banks do not have this on-line banking feature. How does our midsize bank think they have the resources and the knowledge to accomplish this?
10/13/2003
06/02/2003
As part of our BSA Exam we are being questioned about Customs Form 4790. Examiners are indicating that we should be filing this form for foreign wires over $10,000. The form indicates that individuals should file this form. What are banks obligations in regard to this form? Are there special forms or procedure that need to be followed for wires out of the country. Are there special rules under OFAC or the PATRIOT Act?