TOPIC: Compliance

Money Laundering-Cash Deposits--Withdrawals at Casinos

VP at a bank ($91MUSA)
Who else has had experience with suspected money laundering involving cash deposits with withdrawals by debit card at an out of state casino? Cash deposits are made to a personal account, majority under $2,500 to never hit large cash item reports. Deposits are made at 2 different branch locations but not on the same day. Then immediately calls the main office requesting to have debit card transaction & ATM limits cleared.  The same day, multiple withdrawals are made by their debit card at an out of state casino (POS & ATM) for amounts from $64.95 to $504.95. Doing a little research, it appears to have been happening frequently.    

    Require ITIN for resident/non-resident aliens

    Employee at a bank ($210MUSA)
    I would like to recommend to executive management to update our BSA policy to include that we will require ITINs for resident/non-resident alien customers. However, I want to make sure that this does not cut out immigrants or otherwise inadvertently discriminate.