Is there any type of guidance which says what should be stated in each employee's job description and evaluation form with regard to BSA/AML?
I work in the compliance department for a mid-size bank and I am looking for some tips that our account officers could use when questioning our clients about suspicious activity on their accounts (without alarming our clients). Any information provided will be appreciated.
Can you tell me what law regulates Elder Financial Abuse? We have been contacted several times about training, but I have searched both the FDIC site and The Georgia Department of Banking and Finance site and I can't find any requirement for training of bank employees on Elder Abuse. Before I hire someone to come in and train our staff, I would like to read the law/regulation and what is required and what agency requires it.
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
When I complete a SAR, it goes to our BSA compliance officer. The SAR is then edited and sent to FinCEN. It has come to my attention that the SAR does not bear the same content (and is not as informative for law enforcement) as the one I wrote. The edited version is not relayed to the writer and therefore when the FBI speaks to the writer, the information may not match what was in the SAR which can cause a conflict for the writer due to bank procedures allowing only what was in the SAR to be discussed with law enforcement. Can the bank get in trouble for sanitizing the SAR to the point where the information is barely useful?
Two of FinCEN's recent enforcement actions have involved international movement of money through an institution with an inadequate compliance program.
What happens if you don't file a Suspicious Activity Report when you should have?
Yet another bank has fallen under a BSA examination. The Federal Reserve System recently announced a written agreement with Deutshe Bank Trust Company Americas.
Question: We have some accounts that are consuming a lot of time with regards to monitoring and reporting suspicious activity.
FinCEN and the OCC have acted together to place a $24 million fine on the New York Branch of Arab Bank.