Monthly Archive:: April 2021

Q: Are banks required to perform OFAC checks on incoming domestic wire transfers? A: OFAC requires banks to implement a program in accordance with the bank’s size, complexity, risk-factors, and other criteria, in order to block transactions with certain individuals and counties on the ...Read More

MONTGOMERY, Ala., April 30, 2021 — In somewhat of a surprising move, the Alabama Legislature had little-to-no controversies on the House and Senate floors this week.  While that was certainly a good thing, especially for the banking industry, it means a litany of controversial ...Read More

Q: The bank is considering approval for a loan request where one of the guarantors has a significant amount of equity holdings in a business which produces cannabis. There is no expectation that any of the loan proceeds will be used use or co-mingled ...Read More

MONTGOMERY, Ala., April 16, 2021 — The Legislature met for two legislative days this week and have now completed 23 legislative days since the start of the 2021 Regular Session on February 2.  Representatives and Senators dealt with a variety of hot topics this ...Read More

The Legislature met for three legislative days this week and have now completed 21 legislative days since the start of the 2021 Regular Session on Feb. 2.  This week saw debate on a variety of controversial topics, including medical marijuana, lottery and gaming, pistol ...Read More

Q: What constitutes “demonstrable consent” when meeting ESign requirements? Are banks required to collect information that the consumer actually read the disclosure apart from just acknowledgement? A:  The statutory requirement can be found in 15 USC §7001, and reads as follows: “[T]he consumer— (i) ...Read More

Question: Bank XYZ has a Phase II Exemption customer that is no longer eligible for the CTR Exemption since they haven’t had 5 or more transactions over the CTR threshold in 2020. What do they need to do? Answer: Bank XYZ would need to ...Read More