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.
08/18/2008
What are some characteristics to spot a kiting situation on in- and out-going wire transfers?
05/12/2008
Where can I find a form letter that can be used to close a customer's account due to continuing activity from a SAR filing?
01/21/2008
When filling out the CTR concerning incoming wires, why do we have to fill out the wire transfer if it is not cash? If does have to be filled out, where do we list the dollar amount in cash-in?
12/17/2007
Should a SAR be completed on a customer that has had one CTR every week for the last 6 months?
11/12/2007
I have a very technical GLBA question. It is my understanding that if all employees of the bank are required to have deposit accounts then they are also considered a customer under GLBA. If there happened to be a breach of employee nonpublic information through the HR department, say the payroll vendor was compromised and all employees' social security numbers were released, would this not be considered a breach under GLBA and notification required to the affected customers (employees) along with notice to our regulators? Is it possible since the breach occurred through HR department and was of employees' nonpublic information that it is not defined as a breach under GLBA?
10/08/2007
Are banks required to search the OFAC lists on domestic banks when wiring funds?
10/01/2007
If there is a customer that does less than 1,000 dollars of check cashing per day per customer, but transfers money out of the country using an outsourced wire transfer company, how would the bank need to hand this? Would it be an MSB? Does the bank have any risk associated with the wire transfers that it does not perform?
06/04/2007
When conducting wire transfers (incoming or outgoing) is it necessary to check bank names (both foreign and domestic) against the OFAC list?
05/28/2007
Do we need to check OFAC on the payees when the bank’s internal account payable department pays the bills for supplies, services, etc.?