Click to return to BOL home page
Banker Store Read A Reg BOL Insiders Career Connect Learning Connect Bankers Information Network



December 3, 2014
Overdrafts: Latest Regulatory Feedback, Guidance & Best Practices Webinar
David Dickinson and Jerod Moyer

December 4, 2014
Freebies, Bonuses and Contests
John Burnett and Andy Zavoina

December 9, 2014
Bankruptcy: Creditor Do's and Don'ts
Sam Ott

December 10, 2014
Branch Audits: What Is Going On Out There?
Patricia Cashman

December 11, 2014
Setting up New Accounts for Trusts
Mary Beth Guard

December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett



Topic Options
#1292900 - 11/24/09 04:15 PM SARs Shared With Third-Party Service Provider
Norrie Offline
Member

Registered: 02/11/08
Posts: 67
If a financial institution has a contract with a third-party service provider who performs transaction monitoring of the bank's account activity, is it okay for the bank to fax copies of filed SARs to the third-party service provider for follow-up monitoring purposes?

Top
BSA/AML/CIP/OFAC
#1292912 - 11/24/09 04:19 PM Re: SARs Shared With Third-Party Service Provider [Re: Norrie]
John Burnett Offline
10K Club

Registered: 10/27/00
Posts: 30892
Loc: Cape Cod
No. It's not permitted to share the SAR or the fact that the SAR was filed with third parties. Just those who work with them in the bank, audit and examiners, bank counsel and law enforcement.
_________________________
John S Burnett
BankersOnline.com

Top
#1292934 - 11/24/09 04:30 PM Re: SARs Shared With Third-Party Service Provider [Re: Norrie]
Ken_Pegasus Offline
10K Club

Registered: 08/30/01
Posts: 17526
Loc: Another trip around the sun
I'm not certain why a third party would need evidence of prior activity. Regardless, the activity can be described to them without mentioning the SAR filing.
_________________________
"Oh God, they sea is so great and my boat is so small." Breton fisherman's prayer in JFK's office.

Top
#1293200 - 11/25/09 08:49 AM Re: SARs Shared With Third-Party Service Provider [Re: Ken_Pegasus]
joser Offline
Member

Registered: 09/14/05
Posts: 65
Loc: NJ
Just a reminder -- Faxes are not a secure media

Top


Moderator:  Andy Z, Ken_Pegasus