What to Do When Required Information Is Not Provided for Purchasing a Cashier's Check with $8,000 in Currency

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When a person purchases a cashier's check with $8,000 in currency, the bank is required to obtain certain information from the customer as part of the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations. This information includes the customer's name, address, and identification number (such as a Social Security number or driver's license number).

If the customer does not provide all of the required information, the bank must take appropriate action to comply with the BSA and AML regulations. Here are the options:

A. Refuse the transaction The bank may refuse to complete the transaction if the customer does not provide all of the required information. This is the most conservative option for the bank, as it eliminates the risk of noncompliance with the BSA and AML regulations. However, the bank must also ensure that the refusal is not based on discriminatory practices prohibited by law.

B. Complete the transaction and record available information If the customer provides some but not all of the required information, the bank may complete the transaction and record the available information. This option allows the bank to provide the requested service to the customer while still complying with the BSA and AML regulations. However, the bank must make a good-faith effort to obtain the missing information and document its efforts.

C. Complete the transaction and file a SAR If the bank suspects that the transaction may be related to illegal activity, such as money laundering or terrorism financing, it must file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN). In this case, the bank may complete the transaction and file a SAR if it has reason to believe that the customer is deliberately withholding information or engaging in suspicious behavior.

D. Complete the transaction and insist that the customer return with the required information Finally, the bank may complete the transaction but insist that the customer return with the required information within a specified period. This option allows the bank to provide the requested service to the customer while still complying with the BSA and AML regulations. However, the bank must make a good-faith effort to obtain the missing information and document its efforts, and ensure that insisting on the return of the customer is not based on discriminatory practices prohibited by law.

In summary, the bank must take appropriate action to comply with the BSA and AML regulations if a customer does not provide all of the required information when purchasing a cashier's check with $8,000 in currency. The specific action depends on the circumstances and the bank's policies and procedures, but it must be designed to mitigate the risk of noncompliance with the BSA and AML regulations.