Do you have burning questions related to BSA/AML compliance? Struggling with Beneficial Owners, Risk Assessments, Currency Transaction Reports, High-Risk Customers, etc.? If so, we’d like to invite you to join us on July 16, 2024, for our FREE BSA/AML Compliance Q&A Forum where we’ll answer questions such as:
Question: Would you recommend adding marijuana-related Customer Due Diligence (CDD) questions to our account opening forms if we are in a state where it has not been legalized?
Answer: Yes. We would still recommend asking such questions, especially if you have a neighboring state where it has been legalized.
Question: Do you have any advice on which law enforcement or public services we should be coordinating with when it comes to elder financial abuse?
Answer: This can really depend on your location and the specific scenario. There are likely several options, you just need to seek them out. You may also find that some are better than others. We would recommend, at a minimum, that you are meeting the requirements of your state, if any, and any suspicious activity reporting requirements, as part of your BSA/AML program. Outside of that, a lot of institutions start with local law enforcement and then adjust depending on the response they get. For instance, if they feel like local law enforcement really doesn’t do anything, they might move on to their local FBI field office.
Question: If a customer makes a night drop into the depository and then say the next day before cutoff makes an additional deposit that would make up a total beyond the threshold to file would the night drop and the aggregated box be checked along with the customer’s information in Part I? Just wondering.
Answer: While you might aggregate these transactions for reporting purposes, there is specific criteria as to when you should mark the “aggregated transactions” box on the CTR form. The FinCEN CTR FAQs state
Filers should check box 24e “Aggregated transactions” (along with any other box applicable in Item 24) only in the following circumstance: 1) the financial institution did not identify any of the individuals conducting the related transactions, 2) all of the transactions were below the reporting requirement, and 3) at least one of the aggregated transactions was a teller transaction… The option “Aggregated transactions” is not the same as Item 3 “Multiple transactions”, which can involve transactions that are above the reporting requirement. [FinCEN CTR FAQ #27]
All you have to do is register for the Forum on our website. We will answer as many of your questions as we can during the allotted hour.
Published
2024/06/04
