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Atlantic Bank of New York
From: John.Ricketti@ny.frb.org [mailto:John.Ricketti@ny.frb.org]
Sent: Friday, March 18, 2005 10:22 AM
To: firstname.lastname@example.org; Comments; email@example.com; firstname.lastname@example.org
Mr. O'Brien has asked me to respond to your letter dated March 9,2005 seeking feedback on issues involving money laundering and SAR compliance.
Having worked on both the Law Enforcement and Banking side of this issue I have a few thoughts id like to share.
Increasingly the regulators and law enforcement in a post 911 world have been seeking assistance from the banking community in the identification of persons involved in money laundering activities.
We recognize the threat these individuals may pose to our national security, and drug enforcement efforts.
We have assumed a larger burden and are responsible for policing our customers financial transactions, we welcome the opportunity to do our part.
What is problematic though is the increased responsibility with a lack of support from the very agencies seeking our help.
On the "know your customer front" we take great efforts to effectively
identify individuals who bank with us. We request multiple forms of
identification and utilize a private tracking company (Chex systems) which
supplies us with negative banking related reports on a prospective new
customer. We cannot however verify if a Social Security Number supplied by a
prospective customer belongs to that individual. It would
In suspicious cases we rely on Choice point for verification assistance.
In light of a recent breach of security within that company I am concerned
that our continued access to that information may soon be
On the SAR reporting side it seems ridiculous that a person who has been
identified as a money launderer in another institution can move from bank to
bank and have to be re-discovered over and over again. This
Paul De Stefano
|Last Updated 03/21/2005||Regs@fdic.gov|