Bank Secrecy Act/Anti Money Laundering (BSA/AML)
It is acceptable to help a member change their transaction to avoid BSA reporting requirements?
True or False
False
Cash transactions involving more than this dollar amount will trigger the filing of a CTR.
$10,000
It is permissible to notify a member that a SAR is being filed on them.
True or False
$10,000
The USA PATRIOT Act was enacted to further assist in the prevention, detection and prosecution of international money laundering and the financing of terrorism.
True or False
True
What do you do with all checks deposited into Fresh Start Accounts and New Accounts?
Put them on a Check Hold.
FRESH START - Unverified check - 6 business days, Verified Check - 2 business days, $275 available next day. Notice of Delayed Availability of Funds slip
NEW ACCOUNTS - 6 business days (for first 30 days).
What is the criminal practice of processing "dirty" money, through a series of transactions so that the funds appear to be from legal activities?
Money Laundering
A Post Office Box number for the address on a CTR is sufficient?
True or False
False - You must obtain a physical address, the government wants to know where people are located, not where they get their mail.
What are two reasons to file a SAR?
Attempts to avoid reporting or recordkeeping requirements. (Structuring)
2. Activity not consistent with the members business.
3. Members who provide false, insufficient or suspicious information.
4. Unusual activities.
5. Elder Abuse.
6. Identity Theft
7. Check Fraud, Counterfeit Check
What is the program set up to verify the identity of individuals wishing to open an account?
CIP or MIP (Customer or Member Identification Program)
What do you do with the Notice of Delayed Availability of Funds slip on a Large Deposit Hold?
Fill out two - Staple one to the members receipt and scan the other one into DOCMAN with the hold receipt.
What is the law that's purpose is to prevent financial institutions from being used as the go- between for the transfer or deposit of money from criminal activity?
Bank Secrecy Act/Anti Money Laundering
How many days after a cash transaction occurs do we have to file a CTR?
15 days
If 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.
True or False
False
What five must we get for every new member as required by the USA PATRIOT Act?
Full Legal Name
2. Physical Address
3. Government Issued Identification
4. Tax Identification Number
5. Date of Birth
What size of personal check do we need to get Managers or Head MSR approval to accept without putting on check hold?
$2500 and they need to initial the check that they approved it.
Name two programs that fall under the BSA category umbrella?
1. CTR - Currency Transaction Report
2. SAR - Suspicious Activity Report
3. CIP - Customer Identification Program
4. OFAC - (Office of Foreign Assets Control) Checks member info against government watch lists
5. USA Patriot Act - the purpose is to deter and punish terrorist acts, strengthen national security, and improve law enforcement investigative tools
A member cashes a check for $15,000. Later that same day he returns and deposits $12,000 in cash to his checking account. No CTR would be required because the net cash received by the member at the end of the day is only $3,000.
True or False
False. A CTR would need to be filled out for the $15,000 the member got from the cashed check, another CTR would need to be filled out for the $12,000 cash deposited into account.
The number of days the credit union has to file a SAR once suspicious activity has been detected?
30 days
What do you do if there are discrepancies when you run a Credit Report?
Request proof of the discrepancy (Address, Name, SSN) and fill out a Red Flag Worksheet. If unable to provide, fill out a SAR.
On a Large Deposit Hold of over $6725, how much is available the next day, how much in 2 days and how long for the difference?
$275 available next day, $6725 available in 3 days, the difference on hold for 5 business days.
What are the three steps that occur in Money Laundering?
Placement - Criminal places the money into a legitimate financial institution
2. Layering - Structuring (separating the dirty money from its source)
3. Integration - Money returned to the criminal from what seems to be legitimate sources (Property, jewelry, artwork, high-end cars)
What are the 3 things you do after you have filled out the CTR?
Scan it into DOCMAN in the members account.
2. Email KayeLynne with the name and account number of the person you filled the CTR out on.
3. Keep the CTR until KayeLynne emails you that she received it and then delete your copy.
What is the act of splitting large financial transactions into smaller transactions to avoid detection?
Structuring
What is the department that enforces economic sanctions against groups of individuals and countries, such as terrorists and drug traffickers?
OFAC (Office of Foreign Assets Control)
If a deposit is put in the night deposit box and we determine it needs to be put on a hold, we don't need to send them the receipt or the "Notice of Delayed Availability of Funds" slip.
True or False
False. If deposit is not made in person or a hold decision is made after the deposit, we need to send the notice no later than the next business day.