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Question of the Week

Posted: Aug 12, 2021 | Author: Cornerstone Compliance Team
compliance  FinCEN  SAR 

Question: We have a member that has requested us to wire funds in a way that we find suspicious. Do we have to send the wire?

Answer: No. If a member is asking you to conduct a transaction that you feel is a violation of your member agreement or would be a violation of state/federal law or does not seem to have a lawful purpose, you may refuse to send that wire.

Membership in a credit union entitles the member only to a share account and a vote at the annual meeting. Each and every other service you provide is a privilege, and those can be suspended or terminated in accordance with your denial of services policy. Your policy should outline how and to what extent membership privileges are altered so that you apply them equally to your membership in similar situations.

In some instances, member behavior may even compel you to consider expulsion.

If the member request is sufficiently questionable, you should also file a Suspicious Activity Report (SAR) with FinCEN.

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