DOSSIER · FIN

Money Movement Controls

The reporting, liability, and insurance rules that attach to moving customer funds through the banking system.

Brief stack

In this dossier

FIN-06 · 01

Suspicious Activity Reports: Filing Standards and the Confidentiality Rule

8 MIN · FIN

A SAR is the one filing a customer must never learn about. This brief sets out what triggers the obligation, how the 30-day clock runs, who may lawfully be told, and what the statutory safe harbour actually protects.

A SAR is due within 30 calendar days of initial detection of facts that may form a basis for filing, extendable to 60 if no suspect is identified.
Federal law makes both the report and its very existence confidential; a bank may not tell the customer, and disclosure carries its own penalties.
The statute grants a safe harbour from liability to the filer and its people for reporting a possible violation, whether or not the suspicion proves correct.

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FIN-07 · 02

Custodial and FBO Account Structures: Whose Money Is It

8 MIN · FIN

An FBO account holds one balance at a bank and many claims outside it. This brief separates legal ownership from operational control, and sets out the titling, records, and disclosure conditions the structure depends on.

An FBO account is a single deposit at a bank held by an intermediary for identified end users, whose individual claims exist only in the intermediary's ledger.
Pass-through insurance conditions include custodial titling, records identifying the true owners and their interests, and a genuine disclosed agency relationship.
The label 'FBO' on an account title creates nothing by itself; the underlying agreements and state law determine whether a trust or agency actually exists.

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FIN-08 · 03

Wire Transfer Losses Under UCC Article 4A: Who Bears the Fraud

8 MIN · FIN

Article 4A does not ask who was at fault. It asks whether the bank and the customer agreed a commercially reasonable security procedure and whether the bank followed it. This brief walks that analysis and its exits.

Article 4A allocates unauthorised payment-order loss through the security procedure: an order verified under a commercially reasonable procedure can bind the customer.
A customer can shift the loss back by proving the order did not come from anyone entrusted with, or who obtained access through, the customer's own systems.
Consumer transfers governed in any part by the Electronic Fund Transfer Act are excluded from Article 4A, so the two regimes rarely overlap.

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FIN-09 · 04

Deposit Insurance and Pass-Through Coverage for Pooled Accounts

8 MIN · FIN

Pass-through coverage turns one pooled deposit into many insured claims — but only if titling, records, and the underlying relationship all hold. This brief sets out the conditions and the failure modes.

Coverage runs per depositor, per insured bank, per ownership category, at a standard maximum of $250,000; pooling does not by itself increase or reduce it.
Pass-through requires custodial titling at the bank, records identifying each true owner and interest, and a genuine disclosed custodial relationship.
Deposit insurance responds only to the failure of the insured bank, not to the failure of a fintech, program manager, or ledger provider.

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