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April 22
A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

April 29
HSA Basics
Whitney Johnson

April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
Andy Zavoina



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#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?

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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: 29431
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.
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John S Burnett
BankersOnline .com

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#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: 16671
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.
_________________________
We are Boston. We are America. We respond. We endure. We overcome...and we own the finish line. Joe Biden

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#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: 60
Loc: NJ
Just a reminder -- Faxes are not a secure media

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