The following Preview Question from a Learning Connect webinar for the 6-21-16 "Currency Transaction Report Annual Training for the Frontline." This does not appear to match the information from the BOL Compliance Q & A "Report $300 Currency Exchange on CTR?" dated 5-13-13. Your thoughts?
P R E V I E W Q U E S T I O N
Q: We had a customer come into the bank and purchase a cashier's check. He brought in $17,750.00 in cash. The cashier's check was made for $17,725.19, he paid a fee of $3.00 and received $21.81 back in cash. The CTR really doesn't give you a place to put the cash back on the cash in side of the sheet. How would you fill out the sheet so it will balance at the bottom?
A: You would only put on the person's page $17,729 (equals the $17,725.19, rounded up, plus the $3.00 fee). Plus on the cash page $17,729 for the Negotiable Instrument purchased and nothing else needs to be listed.
A DBA account owner withdrew over $10,000. The account is under the owner's Social Security number. The tellers said the transaction was for personal use. Do we include the DBA information on the CTR?
A customer asked me what to do with $13,000 in cash. What is the conversation I should have with the customer?
Do we have to risk rate every consumer account?
I have a BSA question about Phase I exempt customers. I know that Phase II customers' savings accounts can't be exempted, but what about Phase I customer savings accounts? At my institution we have a government entity but they only hold savings accounts with us. Would they still be considered Phase I exempt in our institution at all? And if so, would we have to perform a yearly review on them?
Our bank is basically taking the position that we will not provide services to marijuana related businesses. We need to add this verbiage to our policy but I am unsure of the best approach. My thoughts are..
*We will not provide banking services to marijuana related businesses. (straight forward)
*We will not provide banking services to entities or individuals who activity is not considered legal at the state and federal level. (not segregating a specific business)
*After conducting a risk assessment we have determined that we will not provide banking services to marijuana related businesses.
Any insight you may have is appreciated.
We have discovered a personal checking account that is getting large deposits around $8,000, and then making payroll to workers from this account. The account holder is a permanent resident but we are not sure about the workers. This person is only 20 years old, and getting guidance from his father who is not a citizen. We need your expertise.
Must the CTRs be combined if one corporation owns two DBA accounts?
I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
Are there any different issues to consider when making a real estate loan to a non-U.S. citizen? We have a customer whose husband is not a citizen and they want to purchase a home together here in the U.S.