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#653961 - 12/19/06 12:32 AM Is This a Crime?
BillyBob Offline
Member
Joined: Aug 2006
Posts: 78
We recently discovered that an employee "shared" some nonpublic personal customer information via e-mail. The event was related to an acquisition where an employee of the acquired bank e-mailed customer information to be used at another institution where the individual was going to work following the merger. My question is whether this constitutes a crime that would require a SAR?

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#654074 - 12/19/06 03:43 PM Re: Is This a Crime? BillyBob
SavannahOne Offline
Diamond Poster
Joined: Sep 2005
Posts: 1,163
Georgia
Example: Soon to be ex-Loan Officer emails customer loan trial or loan file data to new bank?

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#654119 - 12/19/06 04:39 PM Re: Is This a Crime? SavannahOne
GuitarDude Offline
Power Poster
GuitarDude
Joined: Nov 2004
Posts: 5,924
So Cal
IMO this is illegal big time, and a huge info security risk. In fact, I remember reading an enforcement action a while back about someone who did this and they were barred from ever working again in a financial institution. I believe it was the OCC who levied the penalty.

It is also most likely a violation of their employment agreement as a theft of information. Lastly, it could (and should) be a violation of your info security policy just by virtue of the fact that this person used email, which is not secure, to transmit protected customer info.

As far as a SAR filing, You can certainly do so if you wish. Even though it may not meet the minimum amount where you have to report, you always have the option of reporting under that amount if you determine it to be appropriate in good faith. FWIW, I would.
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#654257 - 12/19/06 07:11 PM Re: Is This a Crime? GuitarDude
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
As far as the SAR filing.. you do not need a minimum amount to file since it involves an insider.

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#654328 - 12/19/06 08:11 PM Re: Is This a Crime? TXBSA
BillyBob Offline
Member
Joined: Aug 2006
Posts: 78
Thanks to all. The enforcement action was from the OCC in 2003. It's worth looking at: http://www.occ.treas.gov/toolkit/newsrelease.aspx?doc=lir2fvq3.xml

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