BSA-AML Examiner School Case Study eBook
Yes _X No If yes, describe: 25 Commercial customers can originate ACH files through electronic banking in which the amount originated is reported to the board quarterly.
Electronic Payment Services Funds Transfers Electronic cash Third-Party Payment processors
TS&J electronically checks the beneficiaries of all incoming ACH files against OFAC. It is the responsibility of the receiving bank to check the ACH beneficiary of any ACH generated by an TS&J customer. TS&J debit cards are accessible through Apple Pay, Google Pay and Samsung Pay and customers have access via the TS&J Bank App to control debit card such as turn off card, limit spending and control locations. The bank provides domestic and international wire transfer services to customers. Procedures ensure that all incoming and outgoing beneficiaries are checked against OFAC. Wire testing is included in the BSA audit. The following will be obtained for the purchase of monetary instruments between $3000 and $10,000: name, date, type or instrument, serial number and dollar amount. Purchases of multiple monetary instruments during one business day totaling $3000 or more will be treated as one purchase. Gift cards are only sold to customers.
Yes _X
Wire Transfers
No
Yes _X
Purchase and Sale of Monetary Instruments
No
Yes _X
Gift Cards
No
No _X
Yes
Deposit and Nondeposit account Type Services Brokered Deposits Privately-Owned Automated Teller Machines Nondeposit Investment Products Insurance
If yes, describe:
No X
Yes
Concentration Accounts
If yes, describe:
Yes _X_ No If yes, describe: TS&J provides consumer, commercial and real estate loans. Volume of Activity Year to Date 253 Last Year 445
Lending Activities * Consumer, Commercial, Real Estate, Credit Cards
TS&J obtains the required CIP information and checks OFAC on any new loan customer. TS&J offers credit cards through an agent program. CIP for these applicants is done by the agent.
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