My original thread got locked, I certainly hope it wasn't something I said, I'd guess it was more the tangent conversation. If so, I apologize if it was something I posted, and if this thread is subsequently locked for that reason, I totally understand.

I wanted to add a few notes, since I finally had a sit-down with the aforementioned employee's chain of command, from his supervisor, straight up to the CEO. We're small enough that this could be accomplished at one table, so that was helpful!

Until I threw the SAR issue into the mix, and reminded them that fraud is in fact a crime, they didn't seem to think there was any issue they had a right or desire to address. Not unlike what I anticipated. Once I added that bit, they decided to consult our legal resource regarding HR issues, and plan a sit-down with Bob. They don't think Joe did anything wrong by not reporting it (we don't want a "tattle-tale mentality" to become widespread), or that Jane did anything wrong by being complicit with the situation (or even bother to inquire with her to see how much she knows). The don't even want the conversation to be documented in Bob's employee file...because they're concerned about having proof that we knew he didn't something bad. (so they know it's wrong, but they're unwilling to act on it, or tell him to correct it? ugh)

Another fun fact, both the direct supervisor of Bob, and our CEO both had first-hand knowledge from Bob that he had chosen to avoid his obligation to repay the city through some means of deception. He had told them in recent weeks when on separate occasions both had asked about the grant and how he had dealt with it. Neither one thought it was an issue nor did they see a reason to follow-up or tell anyone about it. That really surprised me...kind of seems like that tidbit should find it's way into the SAR narrative as well. At least that gives me a corroborative statement from the subject that he knew what he was doing.

What a mess. Every time I think I've seen it all around here...they find something else to shock me with!

In my opinion you appear to working for an institution with very little in the way of ethics policies. Probably time to make a decision about whether or not you can continue to do so.

And I think the other thread was locked as the discussion has gravitated beyond gathering valuable input from others. What ever happens - happens. Myself, I don't watch daytime or night time soap operas, so I don't care about nor am I looking for further updates.

Original Anon - I don't know if you want to continue to post updates in a public forum. Someone may see it. I would recommend moving the discussion to the Private Forums if you need further opinions. Messy situation. I hope you can get out before it hits the fan.

You probably thought of this already, but...

I suggest making sure that anyone who would be present in the discussion with Bob is reminded that they cannot discuss the potential of a SAR filing with him.

I repeated several times that the discussion of a possible SAR did not leave the room and they couldn't in any way allude to it when talking to the MLO.

CEO and HR talked to him yesterday. Apparently he provided a "very compelling story" as to why he had to move, and they now feel bad for him. He was planning to repay the city in March, on the next anniversary when 20% of the debt would disappear (he says, anyway), and they told him he needs to repay it now. They thought that should end it. They have no problem with him approaching staff and requesting fraud be committed, no problem with the fact that he committed fraud (since it wasn't on the financial's behalf), and think this means we don't need a SAR now. Boy, they just don't understand! Whatever the reason, doesn't negate that he defaulted to commiting fraud instead of trying to solve it in an acceptable way.

I'm trying to explain that me documenting a file and saying why we didn't submit a SAR on this is going to make them look pretty bad, and that less damage would come from filing it at this point. Maybe they'll just have to learn the hard way.

Time to update your resume.

CYA, document every conversation and every recommendation you made. Update your resume. Get the heck out of there. You don't really want to work for such an unethical place do you?

I have a very lengthy and detailed email sent by the CEO, and in the final paragraph it states "A SAR will NOT be filed in this situation". Well, if nothing else, that's a terrific CYA document for me.

Funny, policy states the BSA officer is in charge of all the BSA related decision making. I didn't know they'd updated it to reflect the creation of a new committee that they added themselves to...but, at least they're directly responsible for the fallout now, and not me.

Resume is very much updated and I've been actively searching for a few months now. This place is a powder keg.

You can always have him sign an exception to policy letter/memo for the breach of SAR policy.