Bank's Response to Incomplete Information for Cashier's Check Purchase

A

The acronym "CRCM" stands for "Certified Regulatory Compliance Manager," which is a professional designation awarded by the Institute of Certified Bankers (ICB) to individuals who demonstrate a high level of knowledge and expertise in the field of regulatory compliance.

Regarding the given question, when a person purchases a cashier's check with $8,000 in currency, federal regulations require banks to collect certain information about the customer and the transaction to prevent money laundering and terrorist financing. Specifically, banks must obtain the customer's name, address, and identification number, as well as record the amount, date, and purpose of the transaction.

If the customer does not provide all the required information, the bank has several options:

A. Refuse the transaction: The bank may choose to decline the transaction altogether if it cannot obtain the necessary information from the customer. This is the most conservative approach, as it eliminates any potential risk of noncompliance.

B. Complete the transaction and record available information: The bank may proceed with the transaction and collect as much information as possible from the customer. In this scenario, the bank would still be compliant with federal regulations, but it would be taking on some additional risk.

C. Complete the transaction and file a SAR: If the bank suspects that the transaction may be associated with illegal activity, it is required to file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN). The SAR would trigger an investigation by law enforcement authorities, and the bank would be protected from any liability related to the transaction.

D. Complete the transaction and insist that the customer return with the required information: The bank may choose to allow the customer to complete the transaction but insist that they return with the missing information at a later time. This option allows the bank to continue the transaction while still complying with federal regulations, but it may inconvenience the customer.

In summary, the bank has several options when a customer does not provide all the required information for a cashier's check transaction. The bank may choose to refuse the transaction, proceed with the available information, file a SAR if suspicious activity is suspected, or insist that the customer return with the missing information. Each option carries its own risks and benefits, and the bank must weigh these factors when making a decision.