BSA
True or False: It is acceptable to help a customer arrange a transaction to avoid BSA reporting requirements.
What is false?
CTR IS THE ACRONYM FOR THIS
What is a currency transaction report?
These reports are filed with FinCEN for tracing the flow of currency through the financial system to help identify unusual activity.
This Act was enacted to further assist in the prevention, detection and prosecution of international money laundering and the financing of terrorism.
What is the USA Patriot Act?
AML IS AN ACRONYM FOR THIS
What is Anti-Money Laundering?
A set of procedures, laws, and regulations designed to stop and the practice of generating income through illegal actions.
THE PROCESS OF PLACING, LAYERING, AND INTEGRATING FUNDS TO CHANGE ILLEGAL/DIRTY FUNDS TO LAUNDERED/CLEAN FUNDS
What is Money Laundering?
Placement = dirty money into the FI
Layering = transfers, wires, prepaid devices
Integration = purchase of luxury assets, financial investments
CTR'S ARE REQUIRED FOR ANY CASH TRANSACTION IN EXCESS OF THIS AMOUNT
What is $10,000?
Cash in or out in one business day that exceeds $10,000 on behalf of, or transacted by, the same person. Multiple transactions must be aggregated.
The document provided by a member of an LLC proving its existence?
What is articles of organization?
MONETARY INSTRUMENT REPORTS ARE REQUIRED ON SALES OF MONETARY INSTRUMENTS (PREPAID DEVICES) SOLD FOR CASH IN AMOUNTS FROM THIS AMOUNT TO $10,000
What is $3,000?
Monetary instruments = cashier's checks, money orders, and gift cards. Must record on spreadsheet in the Customer Service Folder in the U:drive when purchased with cash between $3,000 and $10,000.
THE BSA REQUIREMENT FOR ALL FINANCIAL INSTITUTIONS TO CREATE AND IMPLEMENT A PROGRAM TO IDENTIFY THEIR CUSTOMERS
What is the Customer Identification Program (CIP) or Know Your Customer Program (KYC)?
Reasonable belief as to the customer's true identity. We have notices in our lobbies and at the desk of anyone who is opening up accounts.
True or False?
YOU CAN INFORM A CUSTOMER THAT A CTR IS GOING TO BE FILED
What is true?
There is nothing wrong with sharing this information. CTRs are not confidential and we may find that it is necessary to share this information with the customers in explaining the reasoning for collecting certain information from them.
How long must we retain identification/documents after an account has been closed?
(Hint: Between 2-6 years)
What is 5 years?
Beneficial ownership rules require banks to collect information on individuals identified by the person opening an account for an entity under these two prongs?
What are ownership and control prongs?
TRUE OR FALSE?
IT IS PERMISSIBLE TO CONDUCT BUSINESS WITH SOMEONE ON THE OFAC LIST.
What is False?
True or False?
It is possible to be exempt from CTR reporting?
What is true?
Phase I = Domestic Banks, Government entities, Listed Businesses
Phase II = Non-listed businesses- account for 2 months, frequent reportable transactions (5 in 12 months), incorporated or organized under U.S. laws, and is not an ineligible business type
This must have a birthdate, a photograph, and an issue date.
What is required information on a government issued, non-expired identification?
True or False?
VIOLATIONS OF BSA REGULATIONS CAN CAUSE CIVIL MONEY PENALTIES AND POSSIBLE CRIMINAL ACTIONS AGAINST FINANCIAL INSTITUTIONS AND INDIVIDUALS
What is true?
It may also include officers and directors of the financial institution.
Beneficial ownership certification is required to be obtained in these two circumstances?
What is at account opening and upon obtaining information regarding change with the entity?
THE BANK HAS THIS MANY CALENDAR DAYS AFTER THE "BUSINESS" DAY OF THE TRANSACTION TO FILE A CTR
What are 15 calendar days?
The filing must be within 15 calendar days of the transaction.
These are the four pieces of information which the Bank must obtain for every new customer as required by regulation.
What is legal name, date of birth, physical address and tax payer id number?
AVOIDING RECORDKEEPING AND REPORTING REQUIREMENTS, CASH TRANSACTIONS BELOW THE REPORTING THRESHOLDS, REFUSAL OR RELUCTANCE TO PROVIDE ORIGINAL IDENTIFYING DOCUMENTS OR OTHER REQUIRED INFORMATION ARE CALLED THIS
What is suspicious activity?