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#1179763 - 05/08/09 08:38 PM Heartland Security Breach
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
Im sure you are all aware of this security breach a few months ago. I checked in with our VISA dept to see how the processing was going because we chose to re-issue any cards that were listed as a possible compromise. I asked if any fraudulent activity had sufaced with any of our customers cards and the answer was yes. However, I the BSA Officer was never told. The Visa dept sent out dispute forms for the customers to sign. All $ amounts were small, < $500. Should each of these occurences have been documented as suspicious activity, since it is credit card fraud?

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BSA/AML/CIP/OFAC Forum
#1182626 - 05/13/09 06:12 PM Re: Heartland Security Breach dg
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
No. You are not required to file because of the amount. You can find the SAR guidance on pg. 60 of the FFIEC BSA/AML exam manual.

Not only that, but you would be polluting the SAR system (as if it isn't already) with unnecessary filings.
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