06/12/2022
Our President is also Chairman of the Board so he works both at the bank and on our board and has two different levels of responsibility..
My question is for BSA training he completed. He has received training targeted to our board but not the bank targeted BSA training. The curriculum is different at these two levels of responsibility. Our Audit department wrote in an audit that he didn't complete the training for the bank level and argue examiners will look at this negatively. My response it he did training and that is all that matters and examiners won't care about the bank level of the training. Do you feel this could be an issue?
05/01/2022
Can we file a continuing SAR before the 90-day review period?
04/24/2022
We’ve been filing continuing SARs on a business for money laundering. The business has closed, and the activity no longer continued. Must we notify FinCEN that the activity ceased?
04/17/2022
Must non-critical fields be completed on a SAR?
03/20/2022
If we have a FinCEN 314(a) match, besides reporting it on the SISS website,must we file a SAR?
03/20/2022
We are debating Item 24 on the SAR form, Financial Institution TIN and Account affected. The scenario is this - a bank customer cash structured his transaction by cashing two checks on two separate days drawn off of another bank customer. Do you include the account number of the two checks cashed even though the cashier has no ownership to the account?
01/09/2022
If a cash intensive business has a private ATM which they service themselves and they do not have any cash withdrawals from their account, would that in itself be SAR worthy?
11/14/2021
We have a CTR dilemma. A customer came in with $20,000 cash.
- The funds were first deposited into his account.
- He then wanted to purchase a cashier check for $7,000.
- He returned later the same day with an account number of a family member and wanted to transfer $18,000 using the cash deposit and preexisting funds from his account. He is not on the family member's account.
The reason stated was that they are in the process of buying a house and escrow wanted him to show the proof of funds in a statement which was the reason for the transfer. How would you complete the CTR in this situation: is there only one Part 1 (customer) or two Part 1 (customer and family member)? And the $7,000, would be under negotiable instrument and $13,000 under fund transfer?
We also plan on filing a SAR.
11/14/2021
FIN-2021-A002 and FIN-2020-A007 describe Unemployment and Economic Impact Payment Fraud that financial institutions should be aware of. However, the economic payment amounts and most unemployment insurance amounts are below SAR reporting thresholds. Is there a requirement to look for and file a SAR for these types of fraud even if the amount is below the SAR reporting threshold?
11/07/2021
Shall we return a wire sent from Russia when the originator is not on SDN but the originator's bank, SBERBANK is on the e Sectoral Sanctions Identifications List?