We had to file a SAR on a former employee recently (bank took a big financial loss also). Do we need to notify our regulator also? I believe all we are required to do is file a SAR but I want make sure I'm not missing anything. Local authorities were not contacted. This has been very discreet.

Does your examiner check in with you periodically? If so, it should come up in the conversation. They really don't like to be surprised when there is a "big financial loss" due to insider abuse. They will see it anyway when they get ready to examine you because they generally check to see what SARs have been filed.

A couple of things to consider - make sure your bonding company is aware of the loss. Second, if this is a "big financial loss", I don't think you have a choice to not report it to the FBI. Bank embezzlement is a Federal crime and those that help cover it up could possibly be indicted as accomplices or on conspiracy charges. Your regulators are not going to be happy either.

We have had 2 of these in the past. The examiners wanted to see the complete file. (We kept well documented files on each) They were also very interested in any breakdown of controlling factors that may have prevented it. Were changes made to keep it from happening again? Etc. In both instances we notified our local FBI office and filed an SAR. They were below our deductible, so our insurance company was not notified.

Former employee? What kind of financial loss? Is it as the subject title suggests? If so, follow the previously given advice. I'd hate to explain to an examiner (I don't look very good in stripes) why we didn't bother to report "embezzlement" other than through a SAR.

Call your regulator. Soon. You'll find that they're really there to help you. If several agencies get involved in investigating this matter, your regulator can protect you also.

If the "financial loss" is an embezzlement or any other suspected criminal violations, you need to file a Report of Apparent Crime form with the FBI, FDIC, and the US Attorney in your district. This form should be filed no later than thirty days following the discovery.

Can you provide the site that indicates that a Report of Apparent Crime must be filed. If I remember correctly, this was an FDIC form that preceded the modern day SAR

Anon,
Please consider rlcarey's comment...the addressees you mention, as well as the name of the form, indicate you are looking at a form that is obsolete. You can find the current form, a Suspcious Activity Report here:
http://www.fincen.gov/f9022-47r.pdf

After July 1, you will use a slightly revised version that is also on the FinCEN web site.

You mentioned that the loss was large - some questions I would expect an examiner (and your Board for that matter) to ask are: How did it hsppen?, What are you doing to make sure it doesn't happen again? i.e. What new controls, security procedures, etc. have you implemented? How are they working? Is someone making sure they are working?, etc. I have always found that if you have been pro-active, i.e. addressed the problem and its underlying cause, it seems to play out better with the examiner, at least in the long run.