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#3395 - 08/02/01 04:43 AM
Re: Suspicious Activity Report
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Member
Joined: Jul 2001
Posts: 59
ventura,CA,USA
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Hi Bwest, Yes you are correct a report MUST be made and I would advise that you should also ensure that both the offence and a copy of the report filed should be made available to your board. Are you contemplating a criminal prosecution if not have you considered your potential moral obligation to advise local law enforcement in an effort to prevent repetition of a similar offence elsewhere? Matthew Read Compliance Officers Association, Privacy Officers Association, AACFE,MICM,SHRM.
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#3397 - 08/01/01 09:42 PM
Re: Suspicious Activity Report
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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And it would be good to also file a copy of SAR with FBI, especially if you are in a small town where you might not want the local police discussing your loss at the grocery store. The FBI seems to get involved in all bank crimes and the sooner the better, also more discreet. A SAR sent to FinCEN can take 6 months or more to get to the proper FBI office. ------------------ Opinions expressed are not necessarily those of my employer.
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#3398 - 08/02/01 01:14 AM
Re: Suspicious Activity Report
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Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
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The FBI is swamped with bank employee theft and other frauds. You can send a report, but the last I heard was, in Los Angeles Calif. unless the amount was over $1,000,000 the FBI office won't investigate it.
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#3399 - 08/02/01 02:20 PM
Re: Suspicious Activity Report
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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Don, What timimg! I rec'd a confirmation on a SAR filing this morning from the FBI - Mississippi. In short, they are swamped and will not investigate anything, including employee fraud, below $25,000. I guess we should file anyway and let each state notify us of their limits. I still think it is better in very small communities, to report employee matters to the FBI rather than the local police; since almost everyone in a small town is related by birth or marriage and there is too much risk to the bank. Is it possible that the regulators will change reporting thresholds since all this reporting seems to be having a negative impact? Look at the FinCen newsletters and you will see that the number of reports is increasing significantly each year. I don't think that it is all because of new crimes, I believe it is because our regulators are pushing banks to report everything.
------------------ Opinions expressed are not necessarily those of my employer.
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#3401 - 08/02/01 03:00 PM
Re: Suspicious Activity Report
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10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
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David you are absolutely right. We file it once and it becomes available in a searchable database by all the law enforcement agencies granted access. But, in the real world I have been asked for courtesy copies and for copies to be sent to XYZ if I wanted faster action, etc. As to limits, I believe they exist. If it isn't over $X it isn't going to be reviewed because of the way they have to prioritize. (That is where the database should do some aggregation for them. That may not be in use though, as it should be.) I don't believe any of those agencies would publicize what "limits" they may have or where. We know when a SAR is and is not required and those are the limits that matter. It is depressing that we do all this filing and see so little action. But I have had one or two calls on SARs filed that came as a result of database searches. So they may be used more than we realize. I can hope anyway. ------------------ Andy Zavoina Opinions stated are not necessarily that of my employer.
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#3402 - 08/02/01 03:31 PM
Re: Suspicious Activity Report
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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David, I am only suggesting an additional filing in the case of employee fraud, and that to the FBI rather than the local police as suggested by Matthew compliance. The reason being that it can take a minimum of 6 mos. for FinCEN to forward to local FBI and then you may have lost your window of opportunity. As Andy stated, in the real world, those courtesy copies can really help your own bank. For example, in a similar situation (read as been there--done that), the FBI told the bank that if the bank had filed a "courtesy copy" directly with the FBI, that bank would probably have benefitted from recent action by the FBI, but they received the report from FinCEN too late to act. Additionally, the quicker the dirty banker gets reported, the fewer banks he will affect!
------------------ Opinions expressed are not necessarily those of my employer.
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#3404 - 08/02/01 06:13 PM
Re: Suspicious Activity Report
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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Your welcome, and you're right. Address on last page of 5-page SAR form, try http://www.treas.gov/fincen/forms.html ------------------ Opinions expressed are not necessarily those of my employer.
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