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USA PATRIOT ACT. WHAT DOES IT STAND FOR?. Uniting and Strengthening America By Providing Appropriate Tools Required to Intercept and Obstruct Terrorism. The Act is 342 pages 350 subject areas 21 legal amendments 40 federal agencies. Whets The Purpose of the Act.

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usa patriot act

USA PATRIOT ACT

WHAT DOES IT STAND FOR?

slide2
Uniting and Strengthening America By Providing Appropriate Tools Required to Intercept and Obstruct Terrorism
slide3
The Act is 342 pages
  • 350 subject areas
  • 21 legal amendments
  • 40 federal agencies
whets the purpose of the act
Whets The Purpose of the Act
  • To increase anti-money laundering efforts and eradicate the financing of terrorism
  • Title 3 of the Act supplements the Bank Secrecy Act
  • Tighten compliance requirements for all financial institutions and add new record keeping and reporting requirements
what are we responsible for
What Are We Responsible For ?
  • Establishing an anti-money laundering policy
  • Implement minimal standards to verify the identity of each member when opening a new account
  • KNOW WHO YOU ARE DEALING WITH !!!
the big three
The Big Three !!!
  • The Bank Secrecy Act
  • The Customer Identification Program
  • OFAC
the bank secrecy act
The Bank Secrecy Act
  • Established in 1970
  • Requires financial institutions to report certain transactions
  • Designed to deter and detect money laundering efforts
  • Amended approximately 52 times
currency transaction reports ctr
Currency Transaction Reports (CTR)
  • Report Multiple Cash Transactions > $10,000
  • Report Individual Cash Transactions > $10,000
  • The CTR must be sent to the IRS within 15 days of the transaction
  • Transaction over $10,000 over a period of days if deemed suspicious
  • Must keep records for 5 years
who fills out the ctr
Who Fills Out The CTR ?
  • The employee that accepted the transaction
  • Head Teller must approve
  • Must verify identity of the member
do we tell the member about the ctr
Do We Tell The Member About The CTR ?

Absolutely Not !!!!!!!!!!!!

exemptions
Exemptions
  • Banks and Credit Unions
  • Federal, state or local governments
  • Payroll companies
  • Lawyers, accountants, doctors investment advisors, real estate
  • Dealers in automobiles, boats, equipment

etc…

suspicious activity report
Suspicious Activity Report
  • Should file a SAR with the appropriate federal law enforcement agencies and the Department of the Treasury by sending a activity report to FinCen (Financial Crimes Enforcement Network)
  • Should be filed within 30 days
when do you file a sar
When Do You File a SAR ?
  • Insider abuse involving any amount
  • Transactions aggregating $5000 or more when the person can be identified
  • Transactions of $25,000 or more regardless if proper identification can be made
  • Any suspicious transactions or sequence of transactions that are deemed to be unlawful
what is unlawful
What is Unlawful ?
  • Involves money laundering
  • Designed to evade BSA regulations
  • Has no apparent lawful purpose
slide15
SAR
  • Must be filed within 30 days
  • Keep records for 5 years
  • SAR’s are for any transaction, not just cash
  • Exemptions- robbery or theft
  • *** If the suspicious transaction involves currency over $10,000 then both reports should be used
other records required
Other Records Required
  • Monetary transactions between $3,000 and $10,000
  • Wires over $3,000
customer identification program
Customer Identification Program
  • Requires each credit union to implement a written CIP appropriate for its size
  • Accounts opening procedures
  • Reasonable procedures for identifying the identity of each customer
minimum requirements
Minimum Requirements
  • Name
  • Date of Birth for individuals
  • Address
  • Identification number
  • Must keep information for a minimum of 5 years after the account has closed
slide19

Identity Verification ProceduresNew Members – Each individual who establishes a new account with Beacon Credit Union must provide the following information to open a new account:

  • Name
  • Date of Birth
  • Residence Address (Street)
  • I.D. Number (SS No., Tax I.D., Passport, alien reg. card
  • Valid Photo I.D.- Drivers License or Government I.D. (non-expired)
slide20

Existing Members – For existing members who are requesting new accounts or services, identity must be verified using the above process.UNLESS:Identity was previously verified in accordance with the policy and procedures, or the employee has a reasonable belief that the true identity of the member has been established.**Must use CIP on ALL ACCOUNTS opened

procedures for opening new accounts
Procedures For Opening New Accounts
  • Turn to page 3 in Bank Secrecy Act Compliance Program
penalties for non compliance
Penalties for Non-Compliance
  • Civil penalties equal to the amount of the transaction but not less than $25,000 or more than $100,000;
  • Criminal penalties of a fine of up to $250,000, imprisonment up to 5 years, or both;
  • If the activity involves more than $100,000, a fine of up to $500,000, imprisonment for up to 10 years, or both.
slide23
OFAC
  • OFAC (The Office of Foreign Assets Control) is a division of the U.S. Treasury…
  • Administers and enforces trade sanctions…
  • Against (1) countries, organizations, and individuals that sponsor or support terrorist activities, and (2) international narcotics traffickers.
what do we do
What Do We Do ?
  • Compare the list against our member database- Wayne runs the report monthly
  • Compare the list against new members...
  • Compare the list against parties involved in wire transfers…
  • And compare the list against the names on non-member purchasers of monetary instruments.
what do we do if you have a hit on ofac
What Do We Do If You Have A Hit On OFAC
  • Don’t tell the member
  • Continue opening the account or making the transaction
  • Contact Our Compliance Officer Leslie Mehaffey
maximum penalty
Maximum Penalty
  • 5 million dollar fine and up to 30 years in prison
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