Topic: Bank Secrecy Act & Anti-Money Laundering (BSA/AML)
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Should our grocery store customer be registered as a money services business (MSB) or obtain an Illinois license as a currency exchange if it is cashing checks over $1,000 per day per customer? The grocery store is not acting as an agent for another MSB.
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Yes, from what you have told us, the customer is required to register as an MSB with FinCEN. A business that provides check cashing services “in an amount greater than $1,000 for any person on any day in one or more transactions” must register as an MSB. Since the grocery store is not acting as…
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One of our customers is a gas station and convenience store. It has daily cash transactions of over $10,000, so we would like to designate it as exempt from the CTR filing requirements. We are not aware of any potential ineligible activities other than sales of lottery tickets. Are we required to collect the customer’s financial statements before making that designation?
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No. Depending on the customer’s activities, you may be required to collect additional information, but that would not necessarily include financial statements. As part of the exemption process, your institution must “take such steps to assure itself” that the customer is exempt and document “the basis for its conclusions.” For a business that is not…
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Do we need to update account information under the Customer Identification Program (CIP) rules for a trust that has held an account with our institution since 1987? The account lists two signers but no trustees.
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No, the CIP rules do not require you to update the account information for this account, but it may be prudent to obtain additional information to confirm the accountholder’s “true identity,” which in this case would include obtaining information about the trustees for the trust. The CIP rules permit banks to grandfather certain accounts opened…