We are in the process of setting up a SAR Committee to review proposed filing of SAR's after investigations. Can anyone share how they have their committee structured?
Thanks

We recently implemented a SAR committee comprised of BSA Officer, Compliance Officer, CFO, and head of Internal Audit.

We had one at an large bank I used to work for that met twice per month. The BSA Dept. brought the potential SAR filings to the Committee for review via matrix. The committee had the BSA Ofcr, Compliance Ofcr, Security Ofcr, Director of Operations, EVP of Retail, and the Risk Manager.

The matrix was pretty detailed and outlined how the activity was discovered (i.e. from internal SAR worksheet, report review, BSA software, etc.), a summary of the potentially suspicious activity, as well as a rundown of recent activity. This also served as the documentation of the decisions to not file SARS - there was a separate column that was updated with the SAR Committee decision and why it decided not file, etc. Examiners and external auditors liked the format of the worksheet as well as how the committee operated. It was nice, too, because it didn't put the whole burden on any one person.

Cmone, if your Compliance Officer does the BSA Review, then they should not be on the SAR Committee. If your BSA Review is outsourced, then CO participation would be OK.

Ours is BSA Officer, Security/Operations Officer, Auditor, & EVP of the division. Our Compliance Officer does the annual BSA Review, so does not participate.

What if your organization is small and your BSA Officer is your Compliance Officer?

Annual BSA review is performed by our Compliance Auditors. The Compliance Officer is independent of the review function.

I am the BSA officer and Compliance officer but I don't do the annual audit. That is done by the internal auditor. I am interested in setting up a BSA or SAR committee for some dual control over the process.

I'm CO and since Jan., BSA officer and I set up a SAR committee about 6 months ago. I have a Compliance manager that does the monitoring but have asked internal Audit to enhance their SAR/BSA review to make up for my being in a dual role this year.

The great thing about the SAR committee is in documenting the thought process especially when a decision is made not to file a SAR. I have myself, BSA ass't mgr, ops svp& security with others attending on request.

I am curious...how many of you have potential SARs go to the SAR Committee prior to filing? At my institution the SAR Committee meets after the SARs have been filed and the discussion centers around whether to maintain the customer relationship(s) with the SAR subjects.

Has anyone had conversations with their regulator to determine whether the discussion of SAR information in a committee environment (i.e., persons not related to the specific incidents) is pushing the "confidentiality" envelope?

Our BSA committee is comprised of the Executive Committe, BSA/Compliance Officer and Operations Officer.

BSA Committee meets quarterly to discuss cash activity, CTRs & SARs filed, suspicious activity, and other AML/BSA related issues.

BSA Officer is in charge of investigating for SAR reporting and is the individual in charge of the decision making as well. Keep in mind that the BSA officer needs to have sufficient resources and authority to enforce any BSA/AML requirement.

BSA committe discuss whether to maintain or not such customers for whom we have file SARs....

Our SARs go through our BSA Officer, our Operations Officer and our Risk Officer. They are also reviewed by the Board of Directors. I believe that they are presented to the Board after they are filed.

We have an S&S Exam (FDIC) scheduled in September. It will be the first exam after implementation of the SAR Committee. I'll let you guys know if there are any comments.

That would be great. I haven't had an opportunity to discuss with FDIC yet and they regulate several of our banks. I hope to have the opportunity to discuss with several different regulators at the upcoming ACAMs seminar.

Our SAR committee is made up of BSA Officer, CEO, CFO, risk manager and other members of the management team (senior officers)

The regulators are not crazy about us having a SAR committee. They really want the Bank Secrecy officer having full decision power.

We have a BSA committee that meets monthly. BSA officer (me), COO, Chief of Security and Ops AVP. We review previous audits, exemption lists - and I TELL them the Sars that I will be filing. I do ask, on occasion, if they know anything about the customers and these folks have been with our bank and our market for years. There is never any discussion about whether or not I should/should not file the SAR, however. It has been made clear that I make the call. Period.

To clarify my response.........I must make a recommendation and document it. The committee going against my recommendation would require much documentation to support their decision.

I know this is an old post, but we are incorporating a SAR Committee and I would like to hear anyones input on the confidentiality concern and the pros and cons (if any) having a SAR Committee.

We have a SAR committee that meets quarterly. The composition is BSA Officer, Security Administrator, Internal Audit Manager, Branch Operations Officer and Business Services Officer. While the Security Administrator and the BSA Officer are the ones that decide what SARS get filed,the purpose behind our committee is too discussed what actions to take on accounts with repeat SAR activity, e.g. close them, visit them, educate them, ect.

SAR confidentiality is important, but there is nothing that says your bank cannot distribute the information internally, nothing. If you want to review all SAR filings at your Monday morning staff meetings you can, no violation. It would certainly not be prudent, but it would not be a violation.

What you have to do is figure out who "needs" the information and your SAR filing committee does. Some employees need to know a customer is under suspicion, but absolutely do not need to know a SAR was filed. Your committee members need to know everything.

I know this is an old thread, but it is unnerving to me how many posters indicate they are the sole decision maker on SAR filing. I hope their mechanisms have evolved. An SAR filing committee with representatives from different functional areas improves decision making, provides continuity, and gets it through the thick heads of some people that BSA/AML compliance simply cannot be a centralized function.

We have had a SAR Committee for several years comprised of the BSA Officer, Security Officer, Compliance Officer and Head Auditor. The committee meets monthly to review suspicious activity and decide whether to file a SAR, continue monitoring, etc. I am the Compliance Officer and I report the SARs filed quarterly to the BOD in summary format (no customer detail). The CFO and President of the bank read the minutes of the committee monthly as well so they know the detail. We have had several S&S exams while operating with this committee. The examiners (both State and FDIC) love the program and have never taken any exception to it. They have nothing but praises for how it runs. (knock on wood)

Hope this sets some of your minds at ease who are just starting this type of program.

I recently attended a BSA seminar. There was a individual representing each regulatory agency. The idea of a SAR committee was a favorite of all. It was also stated by the panel: there is noting in the regulation that states only one person should know about a SAR filing; it is against regulation for the customer to be told. SAR filings are a "need to know" and the committee "needs to know". Having a diverse group reviewing banking activity decreases the bank's risk and increases the bank's security.

Flip side of that argument: The more people involved in the SAR filing, the more potential leaks there are. While I wholeheartedly support the idea of having a committee or team determine whether to file a SAR, you want to keep the committee reasonably small, and be very selective about who serves.

I also believe that the BSA officer or Security officer should lead that group, and should have the authority to file a SAR over the objections of the committee (but not to kill a SAR if the committee determines it should be filed).

One other argument in favor of the committee approach: It gives you a better chance at grabbing a vacation once in a while!