Examples!!! This is my favorite part of BSA/AML training! It is fun to watch heads snap up when they hear something they might have seen or heard that could possibly be SAR-reportable. And your best resource is absolutely free. Simply go to the websites for FinCEN and the various federal regulators and look at the various enforcement actions and monetary fines for BSA/AML violations and deficiencies. You will find some terrific "real life" examples, such as:
Great Eastern, Miami was fined & cited when a doctor was laundering money via 29 wires in one month totaling over $900,000 coming from & going to foreign countries. Would your wire transfer staff know to raise a red flag on this type of increased activity?
What about the Korea Exchange Bank where a wig importer made cash deposits exceeding a total of $1.2 million?
Another resource is the FinCEN Advisories.
I use examples in my training that I have gleaned from my audits of clients (MINUS names or other identifying information). It is important to try to find something for each functional area. For a proof operator or teller taking mail & night deposits, I use the example of a customer receiving numerous money orders with "odd" symbols in the corners. This is sometimes indicative of a drug supplier receiving payments from his various dealers. They obviously would not write him a check on their personal account and would want some type of record of their payment (so much for "honor among thieves"!).
For those loan officers who think this does not apply to them, I give them the scenario of a used car dealer who sold some his cars out of trust (the bank had floor planned these). Even though he eventually made restitution, this was commercial loan fraud, and as it exceeded $5,000 and the bank could "identify a suspect", it is SAR reportable.
Hopefully, I have given you some food for thought. Good luck and have fun with this!
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Patricia Cashman,CRCM
Cashman Compliance Solutions, LLC
This is NOT legal advice