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#38986 - 10/25/02 03:17 PM Staying out of the Process - (Independent)
Anonymous
Unregistered

Should a compliance officer stay away from involving themselves in filing of CTR's.
I have been asked to review and sign the CTR's before they are submitted. Prior to my designation the banks legal department conducted this review.
They seem to be to busy ( as if I am not) and I have been asked to review and sign all the banks CTR's before they go out.

Doesnt this make part of the process I am charged to review .

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General Discussion
#38987 - 10/25/02 03:23 PM Re: Staying out of the Process - (Independent)
Anonymous
Unregistered

Very often the compliance officer signs the CTR's. The key is to make sure whoever is reviewing them knows what to look for and makes sure they go out correctly. If you have a Teller Manager they may be able to review them and sign off on them, It really depends on who your structured.

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#38988 - 10/25/02 03:54 PM Re: Staying out of the Process - (Independent)
MackenzieS Offline
Diamond Poster
MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
I agree with the prior post. My only concern would be if the compliance and audit responsibilities are shared by the same individual. You would have a conflict of interest there. We have the Teller Supervisors review and sign all CTR's then the form is forwarded to the BSA Manager and audit.

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#38989 - 10/25/02 03:59 PM Re: Staying out of the Process - (Independent)
marcy Offline
100 Club
marcy
Joined: Feb 2002
Posts: 120
In the ideal world, compliance and audit should be out of the process of doing any work that we might have to examine. Reality is quite different in todays banking industry. Margins are so low that we have to wear multiple hats. Just be careful, it's so easy to get drawn into a departmental procedure.
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