I think, Pinkie, that you might want to reconsider your stance on reactions when a subpoena is received. AmSouth dug itself a bit of a hole when it failed to file on activity that was uncovered after it received a subpoena.
Ideally, your normal monitoring would tip you to suspicious activity. But when your staff is poring over its records to pull up copies of transactions to comply with a subpoena, they might very well fall over activity that wasn't detected in a "normal" review. If that activity should have raised suspicions if it had been detected without the subpoena, I think you should file. If the information you turn up as a result of the subpoena doesn't look fishy to you, don't file. But document why you didn't.
Of course, in most cases, you would not be concerned with civil subpoenas (divorce, etc.). But if the stuff you turn up in a criminal investigation subpoena looks bad, you'd better file.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8