Most Popular Compliance Content
Exempt or SAR this Commercial Customer?
10/18/2004
I have a commercial (restaurant) customer who has an on-site ATM. He regularly gets cash to fill the ATM, between $6,000 and $10,000, but never going over that. He sometimes brings in additional money for change. I believe that we should have this customer on our exemption list, but I also believe that the reason he never goes over $10,000 is to avoid a CTR. Our compliance officer said we did not need a SAR because we know what he is doing with the money. We are confident of this. If we know that he never gets more than $10,000 to avoid the CTR, that would qualify as structuring, and should trigger a SAR. Should was file a SAR or have the account exempted?
Many Bank Websites Not in Compliance
10/11/2004
by Andy Zavoina
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SCRA Q&As
10/11/2004
by Mary Beth Guard
Guru BIOS
Getting The Most Out of an "Outside" Trainer by Barry Thompson
10/10/2004
When a financial institution retains a professional trainer or consultant, it's important that adequate information is provided in advance for the trainer on exactly what the goal of the training i
Filing a SAR for Payroll Fraud
10/04/2004
Suspicious Activity Reports (SARs) are ordinarily filed in instances where an employee commits fraud or embezzlement in situations involving monetary transactions (no dollar threshold). Could we file a SAR on two employees who each have falsified their time cards and thus have committed payroll fraud? The amounts in question range from $2,000 to $3,000.