I have read several scenarios on currency in a deceased person's safe deposit box. We have one that I am not sure will meet the definition of "transaction" Case is single renter deceased, box drilled upon non-payment of rent. $18,000 in currency was in the box, that along with other items was verified under dual control and put into safe keeping. Later, staff started tracking down the estate or likely survivor. We found his spouse, and she had no idea he had the box. Upon proper documentation of her right to have box contents, she was given the currency, and no one at the branch considered that a CTR might be required. Since the dollar amount was never placed in a bank account of any kind, there was no transaction that the CTR software could see, so it did not appear there, or in BSA AML monitoring software. It is well past time to file. Do we need to start a back-filing request to FinCEN?
Question about BSA exemption. Customer has two retail stores (same business). Each store has its own deposit account. Can we combine account activity for both CTR reporting and exemption consideration?
Upon identifying specific weaknesses in your AML program that there is not ample time to correct or strengthen prior to an upcoming BSA/AML exam, what action should a BSA Officer take relative to the Board of Directors?
Your Treasury Management (TM) department’s procedures indicate that clients who repeatedly exceed their daily remote deposit capture (RDC) limits are reviewed and reported/referred to BSA. Has your BSA department ever received an internal referral from TM regarding exceeded RDC daily limits?
What is the key to identifying and understanding the bank’s risk exposure and developing the necessary policies, procedures, systems and controls to mitigate BSA/AML risk?
Technology can be a key factor in the success of an AML program. What should be performed on your AML software prior to your next exam?
Is there a regulatory requirement for a bank to have a SAR Committee that reviews and approves every suspicious activity report prior to filing?
What factors should be considered when exiting existing account relationships?
From your review of the new beneficial ownership rule, in your opinion, will both prongs of this rule apply to our customer's customer?
My community bank was cited during a regulatory examination for not providing annual BSA training during the previous calendar year. I am concerned other types of mandatory training may be inadvertently overlooked. What other training are bank employees required to receive annually? Is a master list available somewhere?