BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 10.3: Funds Transfer Recordkeeping (cont.)

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If the originator does not have an established relationship with the institution, does the institution also retain the name and address of the person placing the payment order, their TIN (if none, alien identification number or passport number and country of issuance or a notation of no such record), and a record of the method of payment? 31 CFR 1020.410(a)(2) If the institution knows that the person placing the payment order is not the originator, does it retain the originator's TIN (if none, alien identification number or passport number and country of issuance, if known, or a notation of no such record)? 31 CFR 1020.410(a)(2) If the payment order is made in person, does the institution verify the identity of the person placing the order and retain a record of the type of ID reviewed and the ID number? 31 CFR 1020.410(a)(2)(i)

Y

Y

Y

Y

Y

Y

Comments: No issues were identified.

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