BSA
Who is Citizens Bank's Bank Secrecy Act Officer?
Who is Sharon Weideman
This is the dollar threshold that triggers requirement to file a Currency Transaction Report (CTR).
What is $10,000.01
All transactions, in aggregate, conducted by or on behalf of the same person in excess of $10,000 require a CTR filing.
UNLESS.... The customer has been granted a Phase II Exemption
The bank must maintain record for each bank check or draft, cashier's check, money order or traveler's check it sells or issues for this amount or more in cash.
What is $3,000?
For what reason did Congress pass the USA PATRIOT ACT , enforcing Customer Identification Program (CIP) and Know Your Customer (KYC) requirement?
What is, to help the government fight the funding of terrorism and money laundering activities?
True or False: It is permissible to notify a customer that a SAR is being filed on them.
What is False?
The fact that a SAR has been filed is strictly confidential. Even law enforcement is not allowed to ask whether we filed a SAR. They have access to a database where they can obtain that information. They CAN request the case file for the SAR, which must be accompanied by a judicial subpoena or other court order.
True or False? It is permissible to conduct business with someone on the OFAC list.
What is False?
Customers who may be exempted from CTR reporting by filing this form with FinCEN.
What is a Designation of Exempt Person form?
A review is conducted by the BSA Officer annually thereafter to make sure the entity still qualifies for exemption.
True or False: If a customer purchases a cashier's check for $2,000 and money orders totaling $1,500 on the same day, no record would be necessary because both amounts are below the $3,000 threshold.
What is False?
This is the definition of an account for BSA purposes?
What is any formal banking relationship such as deposit account, transaction account, credit account or extension of credit, safe deposit box?
What are examples of reasons we may file a SAR?
Insider abuse by an employee (any amount)
Violations of law aggregating over $5,000 or more where a subject can be identified and over $25,000 or more regardless of a potential subject
Identity Theft
Transactions aggregating $5,000 or more that involve potential money laundering or violations of the Bank Secrecy Act
When we have direct knowledge that a customer is operating as an unlicensed money services business.
Who is the backup to the Bank Secrecy Act Officer?
Who is Barb Colehour
True or False: A CTR is required for an even up cash exchange.
For example, a customer comes in with $11,000 in odd bills and exchanges them for $20s.
What is True?
Currency exchanges in excess of $10,000 require a CTR filing.
True or False: The bank must maintain different records for non deposit account holders than for deposit account holders when it comes to maintaining information with regards to the purchase of monetary instrument using certain amounts of cash.
What is True? This is why we do not sell these to non-customers.
For account holders: name, date, type instrument purchased, serial #s of instruments, dollar amount of each instrument
Non customers- above and also purchasers address and date of birth, SSN, description of the identifying document used (dl# and state for example)
These are the four pieces of identifying information required to open an account under the Customer Identification Program rules.
Legal Name, Date of Birth, Physical Address, Identifying Number
Bonus Info:
The address for mailing can be a P.O. Box but we must obtain a physical address for BSA records.
See CIP Policy for information on acceptable forms of documentary and non-documentary identification.
True or False: When you notice something that seems suspicious, you should keep it to yourself until you have more details. You don't want to draw attention to it until you have all the facts.
What is False?
Bonus Info:
Suspicious can be anything that doesn't seem right or gives you an uneasy feeling about the transaction or the customer.
True or False: It is permissible to conduct business with someone who is on the FinCEN 314a list.
What is True.
We are required to report matches to the FinCEN 314a list to FinCEN within 14 days of receiving the report but not required to freeze or block funds.
True or False: A customer cashes a check for $15,000. Later that same day, he returns to the bank and deposits $12,000 in cash to his checking account. No CTR would be required because the net cash received by the customer at the end of the day is only $3,000.
What is False?
When aggregating transactions for CTR filing we add deposits to deposits and withdrawals to withdrawals but we do not "net out" that number for CTR determination.
True or False: A purchase of a cashier's check with $12,000 in cash requires a CTR filing.
What is True?
This is the typical frequency that FinCEN issues 314a lists, prompting banks to to search customer databases.
.
What is, every 2 weeks.
Bonus Info:
FinCEN can and has issued updated 314a lists more frequently when there are imminent threats to national security. Example would be when Osama Bin Laden was captured.
This is the person suspicious activity should be reported to.
Your supervisor and ultimately the BSA officer and/or backup.