Our company is a de novo bank and our BSA officer pointed out it was “recommended” by FDIC regulators that banking institutions want to always check their correspondent banking institutions on OFAC anytime they send or get a cable from their store. In my opinion this appears useless and quite extortionate. We send/receive wires through PCBB and I also can not see us the need to always always check OFAC listings because of their name daily. Is this actually necessary?
Suspected Fraud- Funds from ACH Credit on Hold. Right to Refuse Wire Transfer- activity that is unusual
We suspect an individual has been utilized as a mule and recently received a big ach credit. The day that is next he desired to send a worldwide cable because of the arises from the credit. Their description of in which the funds originated from and what they’re used for changed many times; consequently, we froze the account and also have the funds through the ACH credit on hold. Under any obligation to release these to our customer since we suspect he received the funds fraudulently, are we?
Do we as being a bank have actually the best to refuse a wire transfer demand it is suspicious and unusual activity for a particular customer if we feel? This consumer had a cable also come in yesterday and it is now asking for a wire that is international to Nigeria. Needless to say we all know our duties under BSA while the steps we must just take for dubious task, but we additionally would prefer to simply will not conduct the deal completely.