TOPIC: BSA/AML

Bitcoin ATMs

VP at a bank ($379MUSA)
When you identify that an existing customer has a bitcoin ATM located in their business, what type of due diligence do you complete? If the Bitcoin ATM is just being leased and the customer really has no involvement in it, besides possible commission, is full due diligence warranted? Any bits and pieces about bitcoin ATMs is appreciated.

    File a CTR?

    Manager at a bank ($227MUSA)
    Have an interesting transaction.  Our bank holding company (which holds 100% of the subsidiary bank's common stock) has sold treasury stock.  There was one individual present to conduct the transaction.  He bought some shares in his own name, for which he paid by check and $6,000 cash.  He also bought some shares in his father's name, and paid for this with a check and $5,000 cash.  The purchasers are wealthy and it is not believed that the funds are/were derived from nefarious activity.  The money has been deposited into the bank holding company's checking account held at our institution. 

    What is everyone's opinion on this?  Should a CTR be filed?  If so, on the holding company, or on the stock treasury stock purchaser?

      Webinar - 1 CAMS Credit | 2020 Crime Trends & Technology: A Year in Review - Join us Dec 3

      Webinar
      December 03 at 12:30 PM - 01:30 PM EST
      2020 Crime Trends & Technology: A Year in Review
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      1 CAMS credit

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      From the unprecedented impact of the COVID-19 crisis to the historic 50-year anniversary of the BSA, 2020 has been a defining year in financial crime management. With year-end approaching, now is the time to reflect on lessons learned and the road ahead for 2021.

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      Verafin will provide attendees with a certificate of attendance for 1 CAMS Credit. Attendees are responsible for submission of the certificate and reporting of credits to ACAMS.

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          SARS

          Manager at a credit_union ($3.6BUSA)
          Hi, in the wake of the pandemic our BSA team is busier than ever. We've had a significant increase in alerts which is taking away time from other priorities such as SAR and CTR filings as well as 314  alerts.  There's been some discussion internally on how soon alerts need to be tended to while still understanding our regulatory requirement to file timely SARs. What have you done in this area to best maximize efficiencies and minimize burnout? 

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              Webinar - 1 CAMS Credit | 2020 Crime Trends & Technology: A Year in Review - Join us Dec 3

              December 03 at 12:30 PM - 01:30 PM EST
              2020 Crime Trends & Technology: A Year in Review
              What’s on the Horizon for Fraud & BSA/AML in 2021?
              A Special Presentation by Verafin Industry Experts

              1 CAMS credit

              Register Now

              From the unprecedented impact of the COVID-19 crisis to the historic 50-year anniversary of the BSA, 2020 has been a defining year in financial crime management. With year-end approaching, now is the time to reflect on lessons learned and the road ahead for 2021.

              Join us for a special CAMS-accredited, year-end webinar as experts discuss key trends from 2020, such as COVID-19-related fraud schemes, online account takeover, and recent industry calls to modernize the BSA/AML regime, as well as potential challenges for 2021 and the role of technology in mitigating financial crime.

              Register Now

              Verafin will provide attendees with a certificate of attendance for 1 CAMS Credit. Attendees are responsible for submission of the certificate and reporting of credits to ACAMS.

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