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.
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.
Can someone provide some advice on how you pull a market analysis report? We want to look at consumer mostly real estate projects, builder permits, days on market, # of listings vs. # of sales, and things like that. Do you use a system to help with that? How often do you pull this data?