The FinCEN guidance provides substantial clarification around filing SARs and CTRs for marijuana-based businesses. In essence, the guidance states institutions should file SARs and CTRs as if the customer is an illegal business, though not necessarily terminate the account. This could easily cause some confusion, since this deviates from the normal practices; in most cases, an entity known to be operating illegally would be terminated along with the SAR filing.
Most organizations have rather mature and effective transaction monitoring systems in place, but they may not be ready for these new types of businesses and their transaction patterns. For example, with a marijuana dispensary or retailer, many of their customers choose to pay in cash, which will result in large daily cash deposits (more on this later). Transaction monitoring systems will need to accommodate differences in behavior with this sort of business.
In a previous post we looked at some of the challenges posed by the interplay between state and federal laws and the guidance that impacts how banks could service marijuana business that are legal at the state level but not at the federal level. Both the New York Times and the BBC have published pieces about these businesses’ challenges in obtaining banking services because financial institutions are hesitant to service them.
We are only several days into the new year and life insurance executives everywhere are scurrying to figure out how to meet their 2016 goals (or catch up on any 2015 goals). As life insurance companies shift their focus to the customer—the policyholder/prospect and not the agent—improving underwriting has been front and center. Surprisingly, though, many insurers remain unaware of the full extent of solutions available to improve their underwriting processes.
As we ring in 2016, the new year promises to be an active year for financial institution (FI) fraud executives. We’re still in the thick of the U.S. migration to EMV, and many FIs are still scrambling to get their cards out the door. FIs that are ahead of the game are already reaping the results—one executive who I interviewed from a large FI said its migration is 90% complete, and it already saw a 25% drop in counterfeit card fraud in Q4 2015.