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BSA/AML/CIP/OFAC Forum
Employee SAR
Thread Options
#365299
-
05/31/05
01:07 PM
Employee SAR
BankerMama
Diamond Poster
Joined:
Jun 2001
Posts: 1,543
Are we obligated to file a SAR if an employee is kiting....even an amount below $5,000???
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BSA/AML/CIP/OFAC Forum
#365300
-
05/31/05
02:07 PM
Re: Employee SAR
Anonymous
Unregistered
Yes, there is no dollar amount threshold for insider abuse.
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#365301
-
05/31/05
02:07 PM
Re: Employee SAR
LoisLane
Diamond Poster
Joined:
Oct 2001
Posts: 1,570
Wisteria Lane..
Mandatory levels for reporting include insider abuse involving any amount of money. an insider is any bank employee, officer or director.
I would file the SAR.
_________________________
And where is Superman when I need him?
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#365302
-
05/31/05
02:16 PM
Re: Employee SAR
Richard Insley
10K Club
Joined:
Oct 2000
Posts: 10,180
Toano, VA
Yes. Interview and fire the employee first, then file the SAR.
_________________________
...gone fishing.
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#365303
-
05/31/05
02:21 PM
Re: Employee SAR
BankerMama
Diamond Poster
Joined:
Jun 2001
Posts: 1,543
Thanks guys. My thoughts as well but the wording on the SAR instructions..."known or suspected Federal criminal violation" had me thrown.
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#365304
-
05/31/05
02:33 PM
Re: Employee SAR
John Burnett
10K Club
Joined:
Oct 2000
Posts: 40,086
Cape Cod
Kiting is a federal criminal violation. It's theft from an insured bank.
_________________________
John S. Burnett
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