We have a teller who made several large cash deposits which appeared structured. Funds went out via two large wires to two different foreign countries. Teller claims she brought it over from another financial institution. Anyone ever asked for banking statements from an employee to verify source of funds? I know we have the 314(b) capability (she named a specific bank), but curious if anyone has requested that. Thank you.

We had an employee structuring incident recently. When confronted by her manager and our head of Retail Administration the employee fell all over herself explaining and apologizing and subsequently bringing in evidence of the source of funds. We filed the SAR (of course) but the end decision was to retain the employee. I'm not sure that decision would have been made if her attitude had been less cooperative. The teller that took the transaction was also reprimanded for not reporting it. All were required to repeat their BSA training.

You can ask for anything you want. Either a positive or a negative response to your request will yield new information.

I'd be as interested in the wires as I would the cash. Hopefully, your bank requires a statement of purpose for outgoing wires. That would be one less question you have to ask.

I'm with Ken- I'd want to understand both halves of this series of transactions.

Since she named the bank that she claimed to withdraw the cash from, give 314(b) a shot if you suspect money laundering or terrorist finacing. Of course, if the funds were withdrawn from an account in another persons name (or if the teller is lying), then you won't be able to confirm anything. But you don't lose anything by asking.

You could just ask her to prove it also without involving the other bank. How can bank employees be so stupid to do something like this at their own bank???

Going to agree with Randy. Employees should be treated no differently than customers who may be doing something illicit.

No disagreement here. I was merely supplying a reminder of the reasons for invoking 314(b). If those reasons don't apply, then 314(b) doesn't apply.

In either case, asking the employee to substantiate her claim is a worthwhile step.

Thank you all!

The comments concerning 314(b) and purposes - money laundering- reminded me of some information I found very interesting gathered at a fraud seminar. Read the definition the FBI provides for money laundering (doesn't this basically cover any fraud at a bank? )

https://www.fbi.gov/about-us/investigate/white_collar/money-laundering

Similar situation here - bank employee (not in retail) appeared to have accessed her safe deposit box 3 times in 1 week and deposited $4,000 - $6,000 cash into her account after each visit. Checks were immediately written to our bank in the same amount as the cash deposits to pay down a loan.

I think it's just stupidity. Do we confront the employee or not? Yes, we will still investigate.

You are going to consider filing a SAR for structuring. If you decide not to, then you are going to have to write a memo to file explaining why not. Filing a SAR in these circumstances is the decision to file a series of SARs if the activity continues.

There's not enough time left in my career for me to figure out why bankers do not want to talk to their customers, but employees? Geeze, just ask them!

Simply put: Because it's hard to confront employees of a small institution. That's all.

It's called management. Regulators want banks to have BSA officers with the authority to match the importance of their task. That means the BSA officer has to be able to "not be one of the guys" when it comes to investigating questionable employee behavior. If that's not reasonable at a bank, the BSA officer should pull HR or senior management into the discussion to assist.

Do you think it's easier at a large institution? My experiences show that most small institutions have a higher level of trust and Team mentality. Thus, it should be easier to have a conversation like this. It doesn't have to be confrontational. Rather, just ask them as Elwood said. Explain the BSA requirements (they should be aware of them already) and say "this looks unusual, so I'm asking for an explanation." You can make it hard or awkward, but it doesn't have to be.

I'd sure hate this to be an answer I provide a regulator if they came and asked me why i didn't talk to the employee. As Dave said, it doesn't have to be hard unless you make it so. Assuming you have an internal BSA training program in place, the employee should know about structuring,especially someone serving in a teller role. They should be looking for customers that are doing the same thing, over and above whatever your core system provides for reporting.

David and John, thank you for your answers. You're right, this can be a casual conversation. While we have experience training our employees, confronting them for BSA concerns is rather bizarre because of all the training we give them. Then again, by having this conversation, I don't want to tip them off that we may be filing a report.

Definitely a challenging, learning experience.

Document document document

If you do file on the employee the question from regulators may be why is it not an ex-employee and if you do not file the question will be why not.

Asking the question will not be as difficult once you realize that this employee just gave you a lot of work.

The page you provided is not found.

Well that post was from 2015, so links do get outdated from time to time.

Ah! Didn't notice the date.