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#654199 - 12/19/06 06:20 PM What is it going to take convince people about BSA
murphysgirl Offline
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murphysgirl
Joined: Oct 2004
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Home of the Red Sox
BSA should be the first and the last thing on everyone's mind lately-right? We had a teller (not a new teller either) who openly discussed with a customer who resisted giving him CTR reporting information about structuring! I just completed SAR training, detecting and reporting procedures a month ago! What would you do with this teller? I have already filed the SAR on the customer for attempts to avoid reporting- but how do I get the point across to the front line?
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#654203 - 12/19/06 06:23 PM Re: What is it going to take convince people about BSA murphysgirl
Skittles Offline
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Skittles
Joined: Sep 2002
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TN
Did this person assist them in structuring he transaction to avoid a CTR filing? If nothing less, I would think a memo to the personnel file.
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#654209 - 12/19/06 06:31 PM Re: What is it going to take convince people about BSA Skittles
murphysgirl Offline
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murphysgirl
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Just short of that. He more or less explained to him why he needed the information and then-the customer (of foreign decent I might add) asked how to avoid the report, and then he told him that dividing the deposit is suspicious too, so either way it's not good. It may have been innocent but now I have a very bad example of understanding BSA out on the line and that cannot be good.
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#654217 - 12/19/06 06:44 PM Re: What is it going to take convince people about BSA murphysgirl
TXBSA Offline
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Posts: 170
TX
What kind of disciplinary actions do you have in place. We would give the teller a warning (either verbal or written) about failing to follow bank policies. Telling a customer how to structure transactions may not be in the policy, but you would have a very very very long policy if you added in every scenario to the BSA world. I would make sure to have a personal meeting with the teller and provide extra training for them.

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#654220 - 12/19/06 06:46 PM Re: What is it going to take convince people about BSA Skittles
Titanic Offline
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Titanic
Joined: Feb 2005
Posts: 300
My Workplace
I agree with Skittles.....

On your training program, do you emphasize the consequences of not complying with BSA laws? If so, then the accountability rules will definetively be inforced.....

Certain employees do not understand or do not care about the seriousness of complying not only with BSA but, any other banking law....therefore, we need to have them accountable for what they do or they do not do....

In this particular case, you will need to investigate and figure out if the employee was part of the structuring and how involved was he/she was in the process....

Definetively, counseling and retraining one to one with a memo to file will take place...and if there has been any prior non-compliance issues with the same employee, then you will need to take it to the next level (termination)...
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#654270 - 12/19/06 07:19 PM Re: What is it going to take convince people about BSA Titanic
murphysgirl Offline
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murphysgirl
Joined: Oct 2004
Posts: 269
Home of the Red Sox
After looking into this customer's accounts it was just what it was she answered questions that she shouldn't have and now the customer will be continuously monitored to see if he tries to structure going forward. I do see that he has been making infrequent even dollar amount deposits. Nothing unusual all smaller amounts generally consistent with his opast history and nothing specifically tied to the signs we generally look for. But now we have a trigger for unusual behavior and that is what I am filing on besides the avoiding issue. Thanks all- I ahave reproted the employee to HR and they will take it from there.
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Humility about how little I know has encouraged me to listen more carefully and more wisely.
John Templeton


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#655058 - 12/20/06 08:15 PM Re: What is it going to take convince people about murphysgirl
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,798
Cape Cod
I've said this maybe a hundred times before, but it's worth saying once again --

Most tellers naturally want to be helpful. So bank management should not be overly surprised when a teller tries to explain CTR concepts to a customer. The trouble is that you cannot depend on tellers -- or anyone else -- to accurately relate exactly what you want them to say, and no more or no less.

The wise thing to do is to provide your frontline contact people with the ammunition to provide a canned, consistent, written response when anyone asks about reporting cash transactions to the government. You should deliver a handout that you have either purchased or developed, and that has been reviewed by counsel. That handout should explain when CTRs are filed and why, and that it is illegal to structure transactions in ways designed to avoid the reporting requirements.

Profit Protection LLC (http://www.banksecurity.com) has developed exactly this type of brochure. Using it, or developing your own and insisting that it be delivered in place of any attempt to explain the rules, can give you at least some assurance that your staff isn't trying to "make it up as they go along."

I do hope that your HR department puts your employee on probation and comes down hard if there's a repeat of this sort of behavior.

Last edited by John Burnett; 12/20/06 08:17 PM.
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