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#1526878 - 03/24/11 10:35 PM Should Bank Take Any Action - legal or otherwise?
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
"Through the grapevine", the operations officer hears that one of her very young teller's boyfriend, who is not a customer at all of the bank, is an illegal and is using a stolen ID and SSN.

Since he's not a customer and this was a rumor in a small town, my initial thought is to document, discuss the rumor with select management, and keep an eye on the young teller. Monitor every e-mail, all web activity, items she carries out of the bank at night, etc. I don't see how the bank can really file a SAR, but at least acknowledge and document in a SIR.

Then there's the whole ID theft thing. Since he's not a customer with a covered account, what can we really do?

FYI, the police station is directly across the street from the bank. Maybe they heard the rumor too? smile

Thoughts?

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BSA/AML/CIP/OFAC Forum
#1526930 - 03/25/11 12:27 PM Re: Should Bank Take Any Action - legal or otherwise? Wyogirl
BSABecky Offline
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BSABecky
Joined: Mar 2011
Posts: 126
Seymour, IN USA
At the very least, this isn't a bank violation, as the NRA isn't a client of the bank. I would say that provided the teller doesn't have an obvious change in her own transaction history (suddenly depositing lots of cash, etc) there isn't reason to monitor her e-mail, web activity and such. Unless monitoring every employee like this is par for the course, it seems unnecessary. Her boyfriend is of no consequence to the bank; however if the teller would bring him in to open an account, clearly he wouldn't pass muster with a stolen SSN and ID.

It is not our duty as a bank to regulate illegal immigration, but it's my opinion that we shouldn't circumvent it simply to open accounts/make money. smile
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#1527032 - 03/25/11 02:32 PM Re: Should Bank Take Any Action - legal or otherwise? BSABecky
Wyogirl Offline
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Wyogirl
Joined: Nov 2001
Posts: 713
Laramie, WY. USA
"It is not our duty as a bank to regulate illegal immigration"

My initial reply was just this. I think the reason the Ops Officer and myself are thinking beyond this is the stolen ID and the poor sucker whose ID it is. Of course, as stated, this was heard through the grapevine, but still, our natural thoughts are to try to help. There's just nothing we can do at this point.

Thanks for your thoughts!

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#1527047 - 03/25/11 02:45 PM Re: Should Bank Take Any Action - legal or otherwise? Wyogirl
BSABecky Offline
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BSABecky
Joined: Mar 2011
Posts: 126
Seymour, IN USA
I totally understand what you mean; it drives me INSANE not to be able to just call the police and tattle left and right. grin
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#1527167 - 03/25/11 05:11 PM Re: Should Bank Take Any Action - legal or otherwise? Wyogirl
huezoslb Offline
100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
As Bankers playing Big Brother is NOT our jobs.

Treating this poor teller as "guilty by association" is simply terrible and what's even worse is that you only heard it "through the grapevine."

Originally Posted By: wyogirl
"Through the grapevine", the operations officer hears that one of her very young teller's boyfriend, who is not a customer at all of the bank, is an illegal and is using a stolen ID and SSN.

Since he's not a customer and this was a rumor in a small town, my initial thought is to document, discuss the rumor with select management, and keep an eye on the young teller. Monitor every e-mail, all web activity, items she carries out of the bank at night, etc. I don't see how the bank can really file a SAR, but at least acknowledge and document in a SIR.

Then there's the whole ID theft thing. Since he's not a customer with a covered account, what can we really do?

FYI, the police station is directly across the street from the bank. Maybe they heard the rumor too? smile

Thoughts?

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#1527310 - 03/25/11 07:35 PM Re: Should Bank Take Any Action - legal or otherwise? huezoslb
Tater Offline
Platinum Poster
Joined: Jan 2006
Posts: 642
Missouri
Actually, the BSA rules all but require us as bankers to be the police and Big Brother to anyone we deal with in any way. We ought to get hazard pay for some of the people walking through our doors.
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#1527462 - 03/27/11 09:43 PM Re: Should Bank Take Any Action - legal or otherwise? Tater
AnonRegulator Offline
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AnonRegulator
Joined: Mar 2002
Posts: 451
Everywhere, USA
I don't see anything here to report on a SAR. The point of the SAR process is to report instances in which the bank has been used in known or suspected violations of Federal law or a suspicious transactions related to a money laundering activity or a violation of the Bank Secrecy Act. It doesn't sound like the alleged perp in this case has had any dealings with the bank, so there are no suspicious transactions. The SAR process isn't meant to compel banks to report unsubstantiated rumors that do not involve the bank. And there is a difference between rumors and suspicious activities. AR.

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