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October 24
How to Audit Advertising - Compliance Issues Here, There, Everywhere!;
Patricia Cashman

October 29
Documenting an Applicant's Intent to be a Joint Applicant;
David Dickinson

November 4
Issues with Deceased Customers;
Mary Beth Guard and John Burnett

November 5
Vault Burglaries, Floods, Fires & Other Disasters;
Dave McGuinn

November 6
MLO v LO - Who Has to Do What?;
Jack Holzknecht and Mary Beth Guard

November 13
Domestic Violence & Workplace Violence: There Is A Link;
Shelly Collins and Dana Turner



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?

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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: 30717
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

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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: 17436
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.
_________________________
The world is not a wish granting factory. Hazel Grace Lancaster

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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: 65
Loc: NJ
Just a reminder -- Faxes are not a secure media

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