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#1543571 - 04/29/11 06:17 PM
SAR Log
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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Just got written up for not having a SAR Log. ANyone have something you are willing to share?
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#1543583 - 04/29/11 06:38 PM
Re: SAR Log
cheech
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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There's no requirement for a log. Was it an auditor or an examiner who claimed there is? Does your policy say you'll keep one?
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1543596 - 04/29/11 06:48 PM
Re: SAR Log
John Burnett
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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He said it was a Fincen requirement, I am trying to google it now to find it.
BTW, it was an auditor.
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#1543600 - 04/29/11 06:51 PM
Re: SAR Log
cheech
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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Never heard of that. Where you might be in trouble is, like John said, your policy states you have one.
I would ask your auditor where in the reg it states that a log is required.
_________________________
My opinions are my own, and not that of my employer.
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#1543601 - 04/29/11 06:52 PM
Re: SAR Log
cheech
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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Found this.....
Under a FinCEN advisory published Tuesday, compliance departments should limit the disclosure of investigations that might lead to SARs to those on a “need-to-know” basis. Reviews of the reports should be held in a designated “restricted area” for SAR viewing, and each instance that a bank employee accesses a report should be logged, according to FinCEN.
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#1543621 - 04/29/11 07:18 PM
Re: SAR Log
cheech
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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Financial Crimes Enforcement Network Advisory FIN-2010-A014 Issued: November 23, 2010 Subject: Maintaining the Confidentiality of Suspicious Activity Reports
Additional risk-based measures to ensure the confidentiality of SARs could include, among other appropriate security measures, limited access on a "need-to-know" basis, restricted areas for reviewing SARs, logging of access to SARs, the use of cover sheets for SARs, or supporting documentation that indicates the filing of a SAR, or electronic notices that highlight confidentiality concerns before a person may access or disseminate the information.
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#1543635 - 04/29/11 07:26 PM
Re: SAR Log
cheech
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Ah! That kind of log. It still doesn't appear to be a requirement, but a suggested way to mitigate the risk of revealing the existence of a SAR filing. So what else have you done to address that risk? It may be that you're adequately addressing it, and you haven't said it in so many words in your risk assessment.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1543641 - 04/29/11 07:29 PM
Re: SAR Log
John Burnett
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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They are kept in an administrative office in a locked filing cabinet, aside from training, polices etc.
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#1543653 - 04/29/11 07:34 PM
Re: SAR Log
cheech
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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IMHO - He was fishing. He was not able to find very much. He even prefaced by saying this is nit-picky but.....
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#1543682 - 04/29/11 08:05 PM
Re: SAR Log
cheech
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Junior Member
Joined: Nov 2009
Posts: 38
Mississippi
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So Does anyone have a SAR log they are going to share?
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Just a Barbie girl, in a bankers world!!
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#1543695 - 04/29/11 08:15 PM
Re: SAR Log
cheech
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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There's not much to this, in substance or otherwise. In essence, SARs are held in a secure storage unit. There is an inventory. Case numbers make development and maintenance of the inventory much easier. (If you're looking for a conceptual model look at the way your bank handles keys for unrented safe deposit boxes.)
* You take a SAR out, you date and initial the log and say why you removed it.
* You put it back, you date and initial the log to that effect.
* Some poor fool checks the inventory from time to time.
You're just lucky he did not write you up for not having cover sheets on each SAR! Now that, that's really a substantive contribution to SAR security.
P.S. If that's all he can find, you need a new auditor.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#1543703 - 04/29/11 08:19 PM
Re: SAR Log
Elwood P. Dowd
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10K Club
Joined: Jul 2001
Posts: 83,226
Galveston, TX
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In most banks that I work with, the BSA Officer has sole access to SARs filed and no one but them has or is granted access, so it makes the SAR log rather moot. In other banks in which SARs are maintained electronically, access is limited and the system tracks access.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1543808 - 04/29/11 11:00 PM
Re: SAR Log
rlcarey
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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In most banks that I work with, the BSA Officer has sole access to SARs filed and no one but them has or is granted access, so it makes the SAR log rather moot. In other banks in which SARs are maintained electronically, access is limited and the system tracks access. Ditto here on both counts. My files are maintained electronically & accessible only to me (& in a week my new assistant, YAY! ) The electronic software "logs" everytime a case or SAR is viewed, so I guess that works for me. For my old paper files, the only thing I've ever logged was on the inside cover when I've mailed supporting docs to Law Enforcement.
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My opinions are my own, and not that of my employer.
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#1543813 - 04/29/11 11:13 PM
Re: SAR Log
WonderWoman
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100 Club
Joined: Mar 2011
Posts: 103
CA
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I don't think SAR logs are required. However, having a SAR is probably a best practice if you don't have an AML tool or you are a manual institution for the purpose of tracking. Auditor's and examiners are very visual and they want to see that you are tracking your 90-day follow up reviews.
I also use a SAR log for my quarterly reporting to the audit committee. I use it to provide stats on the type of suspicious filed (Structuring, kiting, etc) and the total count filed.
And ditto on rlcarey's post about BSA Officers. However, my new credit union I work for shares the SAR info with various depts and management, which I strongly disagree with. In my past banks we would even redact acct #s and client names before providing SAR copiies to auditors/examiners (per that banks policy).
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Phil Weiss, CAMS
My opinions are my own and not that of my employer.
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#1544123 - 05/02/11 05:09 PM
Re: SAR Log
cheech
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100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
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Cheech, Since things are pretty manual for me, i do keep a log on a spreadsheet. My headers include: date filed, accounts, customer, amount, from date, to date, 90 day follow up and reason for filing. Internal Audit and our Regulator really liked it. Definitely not a BSA requirement but really works. I'm looking forward to Verafin within the next couple of weeks. I also keep a log for my SAR referrals. Just got written up for not having a SAR Log. ANyone have something you are willing to share?
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#1544218 - 05/02/11 06:04 PM
Re: SAR Log
huezoslb
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Curious, huezoslb. Where did you hear about Verafin?
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1544222 - 05/02/11 06:12 PM
Re: SAR Log
John Burnett
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100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
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I wanted Bankers Tool Box but our former CIO was the one who ironed out the details. I have no idea how he heard of it.
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#1544514 - 05/03/11 12:11 PM
Re: SAR Log
huezoslb
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Gold Star
Joined: Apr 2004
Posts: 461
Just a short drive from Lake E...
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On my log like huezoslb's, I added date reported to the board of directors.
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#1544816 - 05/03/11 06:10 PM
Re: SAR Log
Bank Angler
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100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
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OK, this is not a log of SAR's - this a log of anyone who has accessed, such as me (BSA Asst.), BSA Officer, Auditors, Examiners.
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#1544838 - 05/03/11 06:39 PM
Re: SAR Log
cheech
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Power Poster
Joined: Oct 2009
Posts: 3,927
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No such log kept here. I file SARs in a locked cabinet and am the only one with access.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1545014 - 05/03/11 08:38 PM
Re: SAR Log
Doug Hendrickson
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Platinum Poster
Joined: Feb 2007
Posts: 827
In the Sun
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I keep the SARs in a locked file cabinet and I am the only one with a key. I did have to give them to the examiners recently and once they reviewed them they went into a locked vault at the main office by a member of the SAR committee. The only log I keep of them is my 90 day review where I list all the SARS, the status, the date reviewed, and comments on if the behavior has or has not continued. Again, the log is kept in my cabinet.
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Faith is seeing light with your heart when all your eyes see is darkness...
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#1545278 - 05/04/11 01:56 PM
Re: SAR Log
Lele
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Georgia Plum
Unregistered
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Under lock and key, only accessable by me.
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#1545394 - 05/04/11 03:16 PM
Re: SAR Log
huezoslb
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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Definitely not a BSA requirement but really works. I'm looking forward to Verafin within the next couple of weeks. I also keep a log for my SAR referrals.
Verafin is great for logging who accesses the SAR in the software - their audit logs are extensive.
_________________________
My opinions are my own, and not that of my employer.
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