4 ms·

Well, no. I wish that was the case but no. You would be surprised how invasive BSA law is. The main reason banks basically gave in on SARs was the legal protect

Well, no. I wish that was the case but no. You would be surprised how invasive BSA law is. The main reason banks basically gave in on SARs was the legal protection they have for it. This coupled with little average teller is trained results with suspicious activity report stemming from customer saying 'none of your business' to a teller. And I assure you that when auditors ask an officer question why SAR was not filed ( most recent Moneygram case ), BSA officer is sweating bullet. So based on current setup in US, it is banks' responsibilty. And just to add to this, this scheme is being actively copied across the world. FinCEN case link: https://www.fincen.gov/news/news-releases/fincen-assesses-1-million-penalty-and-seeks-bar-former-moneygram-executive https://www.fincen.gov/news/news-releases/fincen-assesses-1-...

toomuchtodo 6y ago
I think we might be taking past each other. A bank and money transmitters are required to meet AML and KYC requirements (in this case, making sure the illicitly obtained funds aren’t laundered with mules or other means), but I propose that it’s the state unemployment insurance department’s responsibility to put benefits into the right deposit accounts in the first place.
- A4ET8a8uTh0 6y ago
  My bad. I completely misread your post. I never thought of that to be honest. My first reaction is hesitation, but it is mostly, because I am not sure how that would work in practice.
  - toomuchtodo 6y ago
    My Citibank credit card pulls in my Chase deposit account details using my Chase login and password (I assume using Plaid under the hood). Perhaps something similar between unemployment systems and your bank, as the bank has already done all of the hard KYC work. They’ve got your PII (including SSN), and your account numbers. Use SSN as the key (I know, I know, we need to get away from the SSN as a citizen ID, baby steps) between the two. You also get to piggyback on 2FA/MFA systems banks have in place.

toomuchtodo 6y ago

I think we might be taking past each other. A bank and money transmitters are required to meet AML and KYC requirements (in this case, making sure the illicitly obtained funds aren’t laundered with mules or other means), but I propose that it’s the state unemployment insurance department’s responsibility to put benefits into the right deposit accounts in the first place.

A4ET8a8uTh0 6y ago
My bad. I completely misread your post. I never thought of that to be honest. My first reaction is hesitation, but it is mostly, because I am not sure how that would work in practice.
- toomuchtodo 6y ago
  My Citibank credit card pulls in my Chase deposit account details using my Chase login and password (I assume using Plaid under the hood). Perhaps something similar between unemployment systems and your bank, as the bank has already done all of the hard KYC work. They’ve got your PII (including SSN), and your account numbers. Use SSN as the key (I know, I know, we need to get away from the SSN as a citizen ID, baby steps) between the two. You also get to piggyback on 2FA/MFA systems banks have in place.