Currency Transactions Reports (CTR)
What is the purpose of filing a CTR?
Currency transaction reports are used to assist financial institutions with identifying money laundering or other illegal activities.
How long does HNCU have to file a SAR?
30 calendar days after the initial date of detection.
What does FinCen do?
FinCEN’s mission is to safeguard the financial system from illicit use and combat money laundering and promote national security.
What are five pieces of information that a member must provide in order to open an account under the CIP requirements?
Name
Date of birth
Address
Identification (social security number/EIN)
Street address
When is a CDD required?
When is new business relationship is established
How many days does HNCU have to properly file a CTR?
15 days
When is the credit union required to file a SAR?
When it detects a known or suspected criminal violation of federal law, a suspicious transaction related to potential money laundering, or a violation of the Bank Secrecy Act (BSA).
Yes, each transaction is subject to being checked against OFAC to ensure it is not a prohibited transaction.
What is the purpose of the CIP Program?
The program accomplishes several things. First and foremost, it helps to ensure the safety and security of our Country by verifying the identity of those men and women who use our financial institutions.
How much does an individual have to own to be classified as a beneficial owner?
25%
When is HNCU required to file a CTR?
When a deposit, withdrawal, exchange of currency, involves more than $10,000 in currency.
Can we disclose to a member that we are filing a SAR?
No, never!
What does OFAC stand for?
Office of Foreign Assets Control
What are the most common acceptable forms of ID? List at least 3.
Drivers License, passport, State issued ID
What program does HNCU use to monitor business relationships?
Verafin
Name at least five pieces of information required to fill out a CTR?
Name of individual conducting transaction(not account owner)
Address
Identification (ex. driver licenses)
Social Security Number
Amount of transaction
What type of information should be gathered if a SAR is warranted?
Who’s involved?
What happened?
When did it happen?
Where did it happen?
Why is the activity suspicious?
What is the purpose of OFAC?
OFAC publishes lists of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific.
What are two acceptable documents that are required to establish an account for a minor?
Social security card/Birth certificate
What is Customer Due Diligence?
Customer Due Diligence (CDD) is the act of assessing your customers’ background to determine their identity and the level of risk they possess. This is done by assessing a customer’s name, photograph on an official document and residential address.
Member makes a deposit a $7k deposit on Monday at 9 am. The member leaves and comes back at 4:30pm on the same day, and deposits $4k. Does this situation warrant a CTR?
Yes, both transactions occurred on the same business day.
Member comes into the branch once a week with $5,000 in hundred dollar bills. The member deposits $2,500 into checking account then asks for smaller bills with the other half. When teller asks where funds are coming from, member would not say. Would you or would you not file a SAR?
Since this a occurring weekly, a SAR should be filed.
Non- Member comes in to an On-us check that a HNCU member wrote. You run the non-member through OFAC and the non-member name comes back on the OFAC list, what do you do?
Per OFAC you can not do business with anyone on the list. So, you will not be able to cash the check.
How long must HNCU retain identification/documents after an account has been closed?
(Hint: Between 2-6 years)
5 years
How do you identify who a beneficial owner is for a business account?
–Obtaining a certification from the individual opening the account on behalf of the legal entity member, (certification form located in appendix A of this regulation) or
–Obtaining from the individual the information required by the form by another means provided the individual certifies to the best of his or her knowledge, the accuracy of the information