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#365299 - 05/31/05 01:07 PM Employee SAR
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Are we obligated to file a SAR if an employee is kiting....even an amount below $5,000???

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BSA/AML/CIP/OFAC Forum
#365300 - 05/31/05 02:07 PM Re: Employee SAR
Anonymous
Unregistered

Yes, there is no dollar amount threshold for insider abuse.

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#365301 - 05/31/05 02:07 PM Re: Employee SAR
LoisLane Offline
Diamond Poster
LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
Mandatory levels for reporting include insider abuse involving any amount of money. an insider is any bank employee, officer or director.
I would file the SAR.
_________________________
And where is Superman when I need him?

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#365302 - 05/31/05 02:16 PM Re: Employee SAR
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
Yes. Interview and fire the employee first, then file the SAR.
_________________________
...gone fishing.

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#365303 - 05/31/05 02:21 PM Re: Employee SAR
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Thanks guys. My thoughts as well but the wording on the SAR instructions..."known or suspected Federal criminal violation" had me thrown.

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#365304 - 05/31/05 02:33 PM Re: Employee SAR
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Kiting is a federal criminal violation. It's theft from an insured bank.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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