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#2003933 - 03/25/15 03:44 PM Subpoenas
Calmeida12 Offline
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Do any of you in BSA review all subpoenas received by the bank or just the grand jury subpoenas? Thank you.

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#2003946 - 03/25/15 04:20 PM Re: Subpoenas Calmeida12
P*Q Offline

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All since I head up BSA, Ops and Compliance and am keeper of the records.

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#2003991 - 03/25/15 05:53 PM Re: Subpoenas Calmeida12
AMLMGR Offline
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We currently review all GJS, as well as any subpoenas from OCC/CFPB, and SEC. Other areas review subset of Administrative for Fraud related issues. Our fulfillment area also may refer other subpoena's over if certain key words are in the verbiage (for example, SAR).

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#2003997 - 03/25/15 06:12 PM Re: Subpoenas Calmeida12
PrimeTime Offline
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We review pretty much anything that gets thrown our way. In addition to subpoenas, we also have any levies forwarded our way so that we can take a look at customer activity before/after the levy for evidence of possible tax evasion. Just another source to start a review of customer activity.
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#2007089 - 04/09/15 03:49 PM Re: Subpoenas Calmeida12
Lilly C Offline
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I head up BSA and Compliance. I review anything that comes in.

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#2007229 - 04/09/15 08:39 PM Re: Subpoenas Calmeida12
Sunshine Lady Offline
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I am in BSA and I do not review those type of documents. There is another department that handles those.
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#2007281 - 04/10/15 11:54 AM Re: Subpoenas Calmeida12
JacF Offline

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Like others in this thread, I'm both BSA and the first stop for subpoenas and such, so I see them all anyway.

That said, and subpoenas or warrants related to a criminal matter trigger a due diligence review of the customer's relationship to determine if any reportable suspicious activity is present.

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#2007289 - 04/10/15 12:49 PM Re: Subpoenas Calmeida12
PrimeTime Offline
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Our situation may be a bit different, however our BSA department reviews all subpoenas, despite the fact that we are separate from Compliance. There was motivation to do this due to a SAR filing we submitted and then during the 90-day review period someone stumbled across a subpoena for said customer, which then warranted a tax evasion aspect of the filing. We figured we'd make ourselves look a bit better next time by being aware of them prior to the filings, and also to use them as a potential starting point for an investigation.
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#2007687 - 04/13/15 05:57 PM Re: Subpoenas Calmeida12
WonderWoman Offline
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gone fishin'
We have a back office that handles all subpoena requests - however they forward any criminal related ones (GJ, State, etc ...) to us for review for suspicious activity.
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#2007843 - 04/14/15 01:26 PM Re: Subpoenas Calmeida12
P*Q Offline

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Personally I'd rather see them all rather than rely on employees to always make the best judgment on what they should send me and what they shouldn't, plus, even if it's not criminal, there may be other reasons we're "watching" a customer so that much more knowledge and info is a plus IMO. Plus volume isn't such that it's excessive work.

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#2007874 - 04/14/15 02:10 PM Re: Subpoenas P*Q
WonderWoman Offline
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Originally Posted By P*Q
Personally I'd rather see them all rather than rely on employees to always make the best judgment on what they should send me and what they shouldn't, plus, even if it's not criminal, there may be other reasons we're "watching" a customer so that much more knowledge and info is a plus IMO. Plus volume isn't such that it's excessive work.


Our volume is too much to get them all. But we do get a monthly spreadsheet that shows them all & we can reconcile that way if we feel they missed one.
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#2008070 - 04/14/15 07:38 PM Re: Subpoenas Calmeida12
P*Q Offline

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That works too. smile

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