10/26/2009
We have an attorney who wants to open an escrow account; however, the funds are from an estate that is being contested. He wants to open the account with the deceased's SSN. Should he not have to get a tax ID number?
10/19/2009
I work in bank fraud cases. We have a case management system in which we input all of our fraud cases (forgeries, counterfeit checks, unauthorized check card trans,etc...). We are trying to make a determination as to the difference between "recovery" and "loss avoidance" when it comes to bank fraud. Could you please help with a clear understanding on what determines in which category an item would fall?
10/12/2009
If a bank relies on an automated ID verification system for both CIP and red flags compliance and there are red flags associated with the name, date of birth, or social security number that go unresolved, are these CIP violations as well as violations of the bank's identity theft program? We only use the system to verify the identity of customer’s who are new to the bank.
10/01/2009
Update: Auditing the AML Program ? What?s New?
By Alan S. Abel, CPA, representing the American Institute of Certified Public Accountants to the Bank Secrecy Act Advisory Group
09/21/2009
If a bank acquires loans through an acquisition, are new CIPs required? What would be involved from a BSA standpoint?
09/21/2009
In determining whether CIP info is required on signers/trustees for a loan on a church, how is a church classified that is operating as a non-profit organization? A church that was incorporated could be classified as a corporation, acting as a legal person. However, civic clubs, etc., are considered entities that are not legal persons, which would require CIP for all signers. Where do non-profit organizations fall in classification?
09/14/2009
It’s my understanding that for CIP of a US citizen a driver’s license number is not a valid ID number, but a that a TIN is required as an ID number, correct? If so, where can I find the citation/rule?
08/24/2009
Does CIP apply if a past customer returns to open new accounts? The customer was previously CIP'd, but currently has no open accounts. An example would be a customer who had a CD, closed it, and six months later returns to purchase another.
08/17/2009
If an irrevocable trust is set up whom do we CIP, the trustees, the beneficiaries?
08/17/2009
We have a business customer who wants to give an employee online viewing access, but the employee is not an authorized signer on the account. Do we have to CIP the employee before we give him access?