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FORGET YOUR PASSWORD? Editor: Lucy H. Griffin Board of Advisors: John S. Byrne, Esq. Robert P. Chamness Cliff E. Cook Phillips G. Gay, Jr. Barbara Hurst Richard Insley Michael D. Maher Robert G. Rowe, III Andy Zavoina |  |
Volume 8, Number 16 This issue went to press on January 30, 2004. Table of Contents SAR Stuff (5 Action Steps) Every so often, FinCEN publishes its SAR Activity Review (it's own SAR, so to speak.) This publication covers some interesting stuff, including SAR filing trends, how SARs have been used by law enforcement and the latest techniques that criminals are using. Flood Insurance: What Causes Civil Money Penalties (5 Action Steps) Compliance Action offers some advice on how to make sure you avoid your bank getting into Flood Insurance "deep water". We have taken a look at the penalties for 2003 and compiled a chart to help show the relative significance of these penalties. Flood Act Violations: 2003 Civil Money Penalties (CMPs) (Chart) Compliance Notes
What is compliance and how much is enough? One approach to compliance is to do precisely what the laws and regulations say - no more and no less. The recent publication of the FAQs on the CIP rule provides some implicit guidance on where to draw the line. Compliance Q&A FAQs on CIP FinCEN and the bank regulatory agencies have issued answers to frequently asked questions about the CIP rule. 
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