Tips for looking for financial information and records:
-- Keep abreast of the names of the suspects by using our list. (You can find a link to it on the front page). Circulate it around your bank to your wire transfer area, to the area where you sell cashier's checks and other cash equivalents, and compare the names against your customer database.
-- If you find any matches, complete an SAR accurately and completely. Explain the suspcious transaction as completely as possible in the narrative section of the SAR. Include the following information in the SAR, if applicable: any correspondent bank name, account info, names/locations of business entities, names of cities, countries
and foreign financial institutions linked to the transaction, especially if wire transfer
activity is involved; and account numbers and beneficiary names. IMPORTANT: In addition, on the SAR, check the "Other box on Part III, Line 35(a), of the SAR, and type in "terrorism" immediately following the box.
-- How can you report this information without violating the customer's financial privacy? You are specifically allowed to provide this type of information under the Right to Financial Privacy Act. Section 3403(c) of the RFPA states that a financial institution or its officer, employee, or agent may notify a government authority of the existence of information which may be relevant to a possible violation of any statute or regulation. This is the section that gives you authority to notify the government authorities, but limit the information you disclose to what the statute allows and do NOT attach documentation to your SAR. Turn the documents over only pursuant to a certificate of compliance.
-- Notify the FBI by going through FInCEN, which has set up a special number to facilitate passing leads on to the FBI from financial institutions. The number is 1-866-556-3974. [Note: Using this hotline is voluntary.]
-- Examine the OFAC list. 27 new names were added 9/24/01 and a great deal of additional information was added about those names on 10/01/01. You can get all that information on our OFAC page.
-- If you find a match with the OFAC list, BLOCK the accounts, freeze the funds, and report to OFAC immediately.
-- Also, block any new transactions with affected individuals and entities.
[This message has been edited by Mary Beth Guard (edited 10-01-2001).]