The Helpline may have heard of such a thing, but it sounds like unringing the bell to me. Just amend it and say whatever needs to be said.
Please note this quote from FinCEN guidance issued this month:
An effective governance structure should allow for the BSA/AML compliance function to work independently(emphasis supplied) and to take any appropriate actions to address and mitigate any risks that may arise from an institution’s business line and to file any necessary reports, such as Suspicious Activity Reports (SARs).
If you are wanting to unring the bell because management disagrees with a decision to file a SAR, your bank is sending exactly the wrong message. Yet, knowing that, I would still probably do it if that is what management wanted because it would draw regulatory attention to the weakness in our structure.
Last edited by Ken_Pegasus; 08/27/14 12:27 PM. Reason: Add excerpt from Guidance
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.