I never had a three strike rule - it was one and done unless it took sometime to unwind the relationship. 95% of the customers that we filed on were unprofitable to begin with and the continued monitoring, filing and potential for errors that could have resulted in a BSA/AML finding in an examination was just not worth it.
Additionally, these actions should all be pre-outlined in policies and procedures.
The bank should develop policies, procedures, and processes indicating when to escalate issues or problems identified as the result of repeat SAR filings on accounts. The procedures should include:
• Review by senior management and legal staff (e.g., BSA compliance officer or SAR committee).
• Criteria for when analysis of the overall customer relationship is necessary.
• Criteria for whether and, if so, when to close the account.
• Criteria for when to notify law enforcement, if appropriate
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com