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, for our FREE BSA/AML Compliance Q & A Forum where we’ll answer questions such as:
Question: We have a handful of customers who are working with crypto, but we haven’t really done anything about it. What would you suggest we do with them? They are not crypto companies or miners and just seem to be trading.
Answer: It sounds like you have a pretty good handle on the types of activity you have occurring within your bank which is the first step. We would recommend then going the next step by articulating your position on cryptocurrency and what your conclusions are about the activity you’re seeing. For example, does it appear to be higher risk, lower risk, etc.? The key is demonstrating that you have identified the activity, assessed the risk and have proceeded accordingly.
Question: Are Suspicious Activity Reports (SAR) required for entities that receive funds from a marijuana-related business (MRB)? Or, is a SAR just for the actual sale of such products? For example, consider a company that sells baggies to a dispensary. Is a SAR required on the company that sells the baggies?
Answer: Yes. While you can consider the SAR filing thresholds, the marijuana-related SAR filing requirements are generally going to be triggered with any transaction that you know or suspect involves funds related to marijuana sales. Any transaction that involves an MRB or funds from the MRB involves funds from illegal activity in the eyes of the federal government.
Published
2023/06/13
