Blog

17. Marcela____________________.

The bank should develop policies, procedures, and processes indicating when to escalate issues or problems identified as the result of repeat SAR filings on accounts. The procedures should include:

Transactions conducted through International ACH system are not subject of OFAC verification if the financial institution does not do cross border ACH

Prepaid access is defined as access to funds or the value of funds that have been paid in advance and can be retrieved or transferred at some point in the future through an electronic device or vehicle, such as a card, code, electronic serial number, mobile identification number or personal identification number.

5. ¿A qué hora se acuesta Isabel?

Senior management and board of directors do not have a fiduciary responsibility to invest in compliance to protect the bank.

The informal value transfer system (IVTS) poses higher risks of being used by money launderers or terrorist due to the lack of recordkeeping and identification requirements

A bank with a high volume of wire transfers would have a higher risk rating than a bank with a significantly lower volume of wire transfers.

The AML risk rating methodology must be tailored to your institution’s size, customer type, products, and services

Obtaining CDD information is a sufficient risk mitigating factor when providing international funds transfer services.