What compliance risk is there associated with one of our business deposit account customers asking us to cash checks for their employees? The employees do NOT bank with us AND the payroll account is drawn on an outside
I am worried about the CDD and the BSA aspects of engaging in this type of activity. Any thoughts?
When BSA holds an incoming wire because they need more information such as invoices, It is our procedure to send a service message to the originating bank and ask for that required info. Sometimes, we are asked to contact the customer and ask for that information from the customer. Is that against any violations or do you think that could offend the customer in any way? Should a specific dept like BSA, contact the customer for that information to avoid having a dept like customer service, that doesn't have any knowledge on that, say something incorrect?
How do I start preparing for the new Beneficial Ownership/CDD rules?
I need to find out the methodology of BSA audit quality control. Is there a check list to ensure my audit firm is doing a good audit job? (basically evaluate the quality of audit, including scope, procedures and work papers).
With the new CDD Regulations, will we need to verify signers and CIP on participant loans? Also - Is there a specific way to verify the information for CDD with the shareholders of a company?
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?
Your AML investigator has reviewed an account, uncovered suspicious activity and filed a SAR. Should the bank immediately close the account?