FinCEN has provided additional guidance regarding the customer identification program (CIP) responsibilities of securities broker-dealers, including those that are affiliated with financial institutions. The new guidance relates to the common situation where two brokers — an introducing firm and a clearing firm — agree to divide the responsibilities for executing the customer’s order.

Stripped down to its core purpose, the internal auditor’s job is to identify and monitor risk. Indeed, in many financial institutions, the audit manager is also the compliance and risk manager. Particularly in the financial services sector, robust audit practices are the foundation for effective risk management.

Law enforcement agencies review suspicious activity reports filed by banks to detect money laundering and other illegal acts. Although tellers will not actually prepare the form, they should know some of the red flags for illegal activity that would prompt you to notify your supervisor or the BSA officer, who will decide whether to file a SAR.

In late January 2008, the Financial Crimes Enforcement Network (FinCEN) issued interpretative guidance to clarify rules implementing Section 312 of the USA PATRIOT Act (the correspondent account rule). When you present a draft or check to a foreign financial institution for payment, you may submit the check or draft directly to the foreign bank or through a clearinghouse or another clearing bank. The question is whether this type of transaction effectively establishes a correspondent account between you and the foreign bank.