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#363413 - 05/24/05 10:34 PM Suspicious Activity Training
dare2dream Offline
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dare2dream
Joined: May 2005
Posts: 128
California
Does anyone have any good resources?
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BSA/AML/CIP/OFAC Forum
#363414 - 05/24/05 10:40 PM Re: Suspicious Activity Training
Elwood P. Dowd Offline
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Elwood P. Dowd
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FinCEN published a guidance package designed to assist financial institutions in the SAR preparation and to improve the quality of information provided in SAR narratives. The package includes written instruction on developing the SAR narrative and two Power Point presentations. It is located here. (They did a good job with it.)
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#363415 - 05/24/05 11:38 PM Re: Suspicious Activity Training
dare2dream Offline
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dare2dream
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California
Thanks Ken, that's a great start, but what I'm really looking for is examples of suspicious activity, we don't have *a lot* here, so I'm looking for some meaty examples to get people thinking.

Thanks!
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#363416 - 05/25/05 12:12 AM Re: Suspicious Activity Training
PatriciaC Offline
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PatriciaC
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Lewisville, Texas, US
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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Cashman Compliance Solutions, LLC
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#363417 - 05/25/05 01:43 PM Re: Suspicious Activity Training
Angel Eyes Offline
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Angel Eyes
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Posts: 4,599
dare2dream - PM me! I have a list compiled in Word that I have obtained from many different sources over the years. It is broken down by deposit, lending, NDIP, funds transfers and general suspicious activity.

Back when I was a teller, I remember getting a list of "suspicious" transaction types. And that very day I had someone come in with something from the list. Had I not gotten a list, I don't know if I would have know to inform someone about what was going on.
Last edited by Jennifer; 05/25/05 01:46 PM.
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#363418 - 05/25/05 01:53 PM Re: Suspicious Activity Training
Texas Boy Offline
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Joined: May 2005
Posts: 1,717
Jennifer, Is it possible I could get my hands on your list of examples as well?
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#363419 - 05/25/05 02:47 PM Re: Suspicious Activity Training
CalifDreamin Offline
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CalifDreamin
Joined: Mar 2002
Posts: 2,269
Far from Calif
I agree with PatriciaC...there's quite a bit out there just between the FinCEN web site and the regulator's web sites. Take a look here at the SAR Activity Reviews that have been published by FinCEN. They all contain actual cases. You can also take a look at OCC's publication: Money Laundering: A Banker's Guide to Avoiding Problems which contains law enforcement cases near the end of the publication.

You may also take a look at some of the suspicious activity indicators that are contained in the various examination manuals that the regulators have, then come up with some scenarios based upon those. They generally break them down by bank function which is really helpful.

Hope that helps.
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#363420 - 05/25/05 03:45 PM Re: Suspicious Activity Training
dare2dream Offline
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dare2dream
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California
Thank you guys! I've gone to some of the sources and pulled before, but I'm going to go back through them.... I really want this training to be the "eye opener" training. So I appreciate all your help!
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