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#635213 - 11/07/06 05:32 PM dual control
Simply Sheldon Offline
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Simply Sheldon
Joined: Oct 2005
Posts: 2,047
S.E. TX
Should there be dual control on somebody who reviews an SAR or CTR and another person who issues it?

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BSA/AML/CIP/OFAC Forum
#635214 - 11/07/06 07:30 PM Re: dual control
A_G Online
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Posts: 18,958
It's not really a dual control issue, perhaps segregation of duties is more appropriate (one person completes and another reviews). It's definitely not required that a second indivudal review these items. However, I think that a seconday review for completeness, accuracy, etc. is not a bad idea. I would especially recommend this if audit or exams has commented on errors after reviewing these items.
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#635215 - 11/07/06 09:24 PM Re: dual control
Simply Sheldon Offline
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Simply Sheldon
Joined: Oct 2005
Posts: 2,047
S.E. TX
Thank you very much Audit guy and I must say you are absolutely gorgeous!

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#635216 - 11/08/06 05:21 PM Re: dual control
Dip Offline
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Dip
Joined: Mar 2005
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San Diego, CA
LOL at "gorgeous" AG!

Here's what my bank does...tellers complete CTR's, manager signs, I do a final review before mailing to FinCEN (and I initial in the corner).

If operations staff detect suspicious activity, I have them write a narrative and email it to me. I edit it, add any additional needed info, and input it all into the SAR form. Then, I file the SAR.

If I discover suspicious activity, I do the entire SAR and no one else reviews it, however, the BOD receives a short summary of SAR's each month.
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#635217 - 11/08/06 05:34 PM Re: dual control
A_G Online
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Quote:

LOL at "gorgeous" AG!




I know Dip - second time this week. I thought the name was a dead give away that I was male.
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#635218 - 11/08/06 05:37 PM Re: dual control
bamccull Offline
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bamccull
Joined: Jan 2004
Posts: 50
Hurricane Country
Our process is similar to Dip on the CTR filing. As far as SAR filing we are a small bank (less than $150M) and the filing (or not) of a SAR is made by me but seconded (rejected) by one other SVP, the EVP or the P/CEO. All of this is documented and initialled. The BOD receives a short summary of the filing (or not) of SAR's each month.
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#635219 - 11/08/06 05:57 PM Re: dual control
Dip Offline
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Dip
Joined: Mar 2005
Posts: 6,298
San Diego, CA
Quote:

Quote:

LOL at "gorgeous" AG!




I know Dip - second time this week. I thought the name was a dead give away that I was male.




maybe they think it means you liek to "audit GUYS," you know, liek you check them out??? Ha!
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#644729 - 11/30/06 03:56 PM Re: dual control Dip
angels2mom Offline
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angels2mom
Joined: Dec 2005
Posts: 338
Depends on my mood
I have something else to ask along these lines...what about exemptions from CTR filing. As the BSA officer, I review activity and decide who should be exempted and why. Detailed documentation is kept. I just got an implication that this should be segregation of duties also. We do the same thing on SAR's and CTR's others have mentioned here. Any thoughts on the exemption filing?
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#645201 - 11/30/06 09:22 PM Re: dual control angels2mom
Pinkie CRCM Offline
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Joined: Aug 2003
Posts: 399
KY
Angel,

Question - do you actually perform the due diligence as far as accumulating all the research data, prepare writeups, etc? If not, I would think you've got separation of duties.

Here, we have 2 people that pull all the CTR information, account / statement reviews, create the writeups and do the analysis. They prepare the forms and "recommend" the exemption. All are "discussed" with the BSA Officer who agrees with recommendation and the forms are filed.

Dip and Audit - you two crack me up!!

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