BSA Officer Reporting Directly to BOD
10/02/2006
Should the BSA Officer report directly to the board of directors?
Ryan Rasske
Bio:
As President of Associated Risk Group, Ryan is responsible for corporate administration and the management of sales, marketing and business development. ARG is an affiliate of Associated Banc-Corp ($22 billion bank holding company) that provides compliance consulting to small and mid size financial institutions. Prior to joining ARG, Ryan was employed with the U.S. Secret Service and lived in the Washington DC metropolitan area. His banking career started at E*TRADE Bank where he assumed the role of Bank Secrecy Act and Anti-Money Laundering Officer. In 2003, Ryan was employed at Associated Banc-Corp in Green Bay Wisconsin as Vice President, BSA/AML Director. In that capacity, he was responsible for the bank's Anti-Money Laundering, Bank Secrecy Act and OFAC compliance programs. He conducted several training programs throughout the year specializing in CIP, Identity Theft, Risk Assessment, Detecting and Reporting Suspicious Activity.
Ryan is currently a board member of the ABA National Compliance School and actively participates in the ABA Money Laundering Issues Group. He was a speaker at the 2004 ABA Regulatory Compliance Conference in Chicago, frequently conducts web seminars for Money Laundering Alert and also a member of ACAMS.
Contact info:
Ryan may be contacted via email at: ryan.rasske@associatedriskgroup.com
Questions Answered
Shady Auto Loan Customer
09/25/2006
In reviewing an auto loan app today I noticed the customer has had 13 auto loans in the last 24 months (June '04 to June '06). He trades them in, usually with the same dealer. He has never made more than 2 payments on a loan. He first became our customer in July '02 and through Aug '03 received 9 separate auto loans, with this same pattern - one or two payments and trades off. Three off the loans in his whole portfolio received large principal reductions as one of their payments. None appear to be in cash. Is there cause here for a SAR? Or is this simply an aggravating customer?
ID Verification Via Mail for HSAs
09/18/2006
Many financial institutions that offer health savings accounts (HSA) simply request that the HSA application with initial deposit, and only a copy of an ID as verification be mailed, not presented in-person. With numerous HSA's being established out of state, no in-person verification is requested and seems to conflict with the PATRIOT ACT’s customer profile information requirement. How can our bank open HSA’s and not have the customer do this in-person, can this be done strictly via mail?
Vendor Confidentiality Agreements
09/18/2006
Should our bank have confidentiality agreements with allvendors who provide services to our bank? (ie. on-site paper shredding companies, coffee suppliers, etc.)
Customer Frequently Changes His Address
07/03/2006
We have a customer that changes his address at least once a month, and he did it twice in one month this past time. What do you think he might be up to? Frequent address change requests are suspicious, but what do you think he could be trying to accomplish or hide?
Handling a Breach of Customer Privacy
06/19/2006
We would like information on whether a bank is required to contact regulators and customers when an employee has e-mailed some non-public information of our customers to an employee at another financial institution. The purpose was to get copies of forms, but some information such as loan numbers, loan amounts, and names of customers were on the copies of the documents. Since this information was passed between financial institutions, and all efforts will be taken to inform the other financial institution that this information was passed and must be held confidential or destroyed, does this create the notice requirement for privacy of a breach?
CIP for Non-resident Alien Sole Proprietorship
06/19/2006
Our CIP policy states that for a sole proprietorship, we CIP only the owner following our consumer CIP procedures. Our consumer CIP procedures permit account opening for a non-resident alien without a TIN, and with a signed W-8. What are the requirements if a non-resident alien wants to open an account for a sole proprietorship? Do we not open the account if the owner does not have a social security number?
SAR: Staff Member Disclosed Client Info to 3rd Party
06/19/2006
One of our staff members disclosed client information to a third party. The staff member has been terminated. Do we need to file a SAR?
Member of Publicly Traded Company Exempt from CIP?
03/13/2006
If a person is a member of a publicly traded company, do they fall under the same CIP regulations of the Patriot Act? I have a potential customer claiming that due to his position within a publicly traded company that he does not have to provide this information.
I'm Cleaning up our CIP Files
03/06/2006
I've recently started with a community bank, and began the process of cleaning up our Customer Identification Files. For closed accounts that have incorrect or missing information as required by the Patriot Act, are we required to go back and correct those? If so, how far back do we have to go? If we are unable to obtain the correct information on the closed account, will that become a finding from the auditors?