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#1748246 - 10/10/12 07:48 PM SAR Committee Poll
PeeWee Offline
Gold Star
Joined: Aug 2007
Posts: 254
For those using a SAR Committee, what is the function of your Committee.
SAR Committee
single choice


Votes accepted starting: 10/10/12 07:46 PM
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BSA/AML/CIP/OFAC Forum
#1749392 - 10/15/12 09:08 PM Re: SAR Committee Poll PeeWee
Mbank Offline
Junior Member
Mbank
Joined: Oct 2012
Posts: 33
MS
None, why do you have a SAR committee? You don't need a committee to decide what you though was suspicioius, expecially if they have no idea about BSA/Compliance issues. IMO

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#1749401 - 10/15/12 09:34 PM Re: SAR Committee Poll Mbank
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The reasons to have a committee include:
* establish continuity in decision making,
* avoid making a single individual responsible for making some tough decisions that might be second guessed by management, and
* provide some BSA/AML education for people who clearly have no idea.
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#1750042 - 10/17/12 08:01 PM Re: SAR Committee Poll PeeWee
cheech Offline
100 Club
Joined: Jun 2010
Posts: 207
Chatsworh PA
We have a SAR Committee but have it set up so that the Comittee answers to the BSA Officer - if that makes sense. Senior management can somes add more information or easily explain information.

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#1750170 - 10/18/12 12:55 PM Re: SAR Committee Poll PeeWee
Big Dog Offline
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Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
We use a committee and the members are up on BSA. BSA Officer heads and includes Cheif Risk Officer/Gen Counsel, Br Administrator, Security Officer, Head of OPS. In general, committee follows the recommendation of the BSA Officer, occasional vote to file on items under the reporting threshold in the event it may help LE.

BSA Officer has the ability to file without committee approval on the slam dunks and report to the committee after filing.

Examiners seem to like the committee setup.

Helps to drive home the point that BSA is for everyone and the existence committee is stressed during training.
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#1750683 - 10/19/12 02:41 PM Re: SAR Committee Poll Mbank
S'mark Offline
New Poster
S'mark
Joined: Mar 2012
Posts: 6
Originally Posted By: MBank
None, why do you have a SAR committee? You don't need a committee to decide what you though was suspicioius, expecially if they have no idea about BSA/Compliance issues. IMO


Ditto!!! grin

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#1750789 - 10/19/12 04:47 PM Re: SAR Committee Poll PeeWee
Pamlissa Offline
100 Club
Joined: Oct 2009
Posts: 115
Rosemont, IL
We have a SAR Committee as well. The SAR committee is supposed to vote on the SARs that are not a slam-dunk, but our BSA Officer can overrride and make a final decision. Also, this is problematic because they only meet once a month and with the time restrictions in place, the BSA Officer often has to send them in before the committee is able to meet. In these cases, she passes the SAR through legal to review the narrative, then through one of the SVPs that is an integral part of the SAR committee.

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#1750836 - 10/19/12 05:53 PM Re: SAR Committee Poll PeeWee
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
I'm with the no need for a SAR committee group. I've always made the decision as I've been doing BSA forever and have never had my decision to file or not to file questioned.

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#1750844 - 10/19/12 06:00 PM Re: SAR Committee Poll P*Q
renniks Offline
Diamond Poster
renniks
Joined: Sep 2003
Posts: 2,162
New England
Originally Posted By: P*Q
I'm with the no need for a SAR committee group. I've always made the decision as I've been doing BSA forever and have never had my decision to file or not to file questioned.


Ditto

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#1750975 - 10/19/12 11:12 PM Re: SAR Committee Poll PeeWee
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I have a SAR Committee only for backup when I want to close an account. When the LO gets the request from the CLO, they're less likely to argue.
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#1759844 - 11/21/12 02:15 PM Re: SAR Committee Poll PeeWee
AMLMGR Offline
Junior Member
Joined: Jan 2010
Posts: 35
We have a SAR Committee that reviews higher risk cases or successive cases that assists in making risk based decisions for the bank, as well as obtaining additional information that was not previously obtained by an Investigator. The have no SAR/No SAR decision making. They are comprised of both individuals in Compliance for the bank, as well as higher up managers on the retail side of the bank who may be more familiar with the clients or that business type, as well as their products and how they might use them.

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#1761688 - 11/28/12 05:22 PM Re: SAR Committee Poll PeeWee
CompliKat Offline
Member
CompliKat
Joined: Dec 2009
Posts: 96
We have a SAR committee, they review the SARs before they get filed, meet once monthly, anything they review must be in "ready to file" format. Loosely, the BSA officer decides if it rises to the level of filing and then the comittee decides yes or no.

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#1762589 - 11/29/12 09:58 PM Re: SAR Committee Poll PeeWee
Beachbum, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 482
Knee Deep in Regs
We have just instituted a SAR Committee.Prior to this year we had the BSA Officer and BSA Assist. making the decision,but our examiners were here this Summer and asked why we did not have a SAR committee. (go figure)....
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#1762602 - 11/29/12 10:20 PM Re: SAR Committee Poll PeeWee
joeA Offline
New Poster
Joined: Oct 2012
Posts: 12
We have a SAR committee, it is great way to inform heads of other departments about suspicious activity and get their opinions. If a SAR is obvious we don't have to wait for the committee to file.

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#1762729 - 11/30/12 02:37 PM Re: SAR Committee Poll PeeWee
Blade Scrapper Offline
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Blade Scrapper
Joined: Aug 2004
Posts: 5,912
Outside A Garage
We have a BSA committee that discusses our relationship with repeat filers. They do not make the determination about whether activity is suspicious.
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#1763243 - 12/03/12 02:27 PM Re: SAR Committee Poll PeeWee
ATLbanker Offline
Gold Star
Joined: Sep 2005
Posts: 332
Georgia
Our BSA officer says I am on her SAR Committee. I act as sounding board for her as she thinks through whether to report. I try to be supportive and encouraging. I tell her to file when in doubt and I will back her up if others quetion it. Fortunately, most of hers are easy - structuring so plain most anybody would say so, except for certain members of senior management who would want to know who the customer is related to before they decide. However, there were a few cases that caused us quite a bit heartache.

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