Robert Moore
Registered User
- Messages
- 42
the anecdotal evidence of questions to depositors who want to make sizeable withdrawals of "their" money.
There is the concept of "destination of funds" under AML but it should only really be relevant for very large, complex transactions and not typical withdrawals.Hence the anecdotal evidence of questions to depositors who want to make sizeable withdrawals of "their" money.
They may also ask about withdrawals under anti money laundering (AML) regulations. In fact, they are obliged to in certain cases.I am not aware of the "anecdotal evidence" that banks are asking people about their withdrawals other than asking vulnerable customers where they suspect that they might be the subject of a scam or a fraud.
No, but it's still relevant to this point:But the Deposit Guarantee Scheme was not the subject of my question
A customer would not be standing in that line for deposits covered by the DGS.As a creditor, I would imagine you would stand pretty much in line behind Revenue, liquidators et al should a bank get into difficulties.
That's where we will differ, Brendan, because I do know of questions being raised when withdrawal made.I am not aware of the "anecdotal evidence" that banks are asking people about their withdrawals other than asking vulnerable customers where they suspect that they might be the subject of a scam or a fraud.
In fact, banks have been criticised for not asking people why they were withdrawing money when the elderly customer subsequently handed it to fraudsters.
Brendan
Under AML regulations they are entitled and possibly obliged to ask questions. Especially about the "sizeable withdrawals" that you originally mentioned.That's where we will differ, Brendan, because I do know of questions being raised when withdrawal made.
Akin to asking for Solpadine in a pharmacy here
That's fine. You have more faith in the size of the entire DGS funding than I do. And I would be a very modest depositor, well under the 100k criterion. Not like some of the Silicon Valley guys.No, but it's still relevant to this point:
A customer would not be standing in that line for deposits covered by the DGS.
I never expressed any opinion on the DGS.That's fine. You have more faith in the size of the entire DGS funding than I do.
Yes.However, nobody has answered the fundamental question yet about when you deposit money in an Irish bank. Do you become a creditor?
Thank youYes.
From a bank’s perspective, loans are assets and deposits are liabilities.
Yes, very good point - large complex transactionsThere is the concept of "destination of funds" under AML but it should only really be relevant for very large, complex transactions and not typical withdrawals.
This really depends. The threshold & risk factors for asking for destination of funds is significantly higher than source of funds.Under AML regulations they are entitled and possibly obliged to ask questions. Especially about the "sizeable withdrawals" that you originally mentioned.
AML legislation deals with "transactions" and does not distinguish between lodgements and withdrawals.This really depends. The threshold & risk factors for asking for destination of funds is significantly higher than source of funds.
In addition there is a layer of opertional guidelines from the EBA and the Central Bank. And banks themeselves need to take a risk-based approach.AML legislation deals with "transactions" and does not distinguish between lodgements and withdrawals.
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