Withholding the amount of the transaction to evade filing a CTR.
This should be done when a new product or a change in product services or the expansion of the number of members or offices occur.
This process assists law enforcement in its investigations of illegal activities.
Administers and enforces economic and trade sanctions based on foreign policy and national security goals against targeted foreign counties. This is a separate from BSA.
Compliance program must be tailored to WCCU's risks.
Depositing unlawful cash proceeds into a financial institution.
As long as this is followed, a CTR does not need to be completed.
This report must be filed for cash transactions of $10,000.01 or more by the BSA Compliance Officer. This report must be kept for five years.
The requirements needed for this are:
1. Independent testing of compliance for the BSA/AML.
2. Training of appropriate personnel.
3. A system of internal controls.
4. The designation of an individual to coordinate and monitor.
5. A list of written procedures for the administering the four core elements of CDD.
From this point to $10,000.00 a WCCU employee must verify the persons identification who is purchasing or receiving currency, money orders, cashier's check, traveler's check, credit union drafts or checks. The WCCU employee must keep the documentation specified by BSA and or regulations.
WCCU employees will do this when first opening a member account and will continue to monitor the account for suspicious activity.
A bureau within the U.S. Department of the Treasury which is responsible for BSA compliance and civil enforcement actions.
Occurs when a criminal uses financial transactions or businesses to disguise unlawful proceeds. These can be such transactions as sham loans or false import/export invoices. This allows the money to be laundered back into the criminals pockets.
Prior to opening an account for someone every WCCU employee must request, see and make a copy of: a driver's license; passport; alien registration card; military or government document with a photo on it.
WCCU can be fined and have criminal charges of up to $1 Million dollars or twice the value of the transaction brought against them. WCCU can lose its charter from the state and be unable to operate as a financial institution. Employees can be barred from working in other financial institutions.
This can be completed by WCCU's internal audit department, outside auditors, consultants or other qualified parties.