I'm wondering if anyone uses any type of "Suspicious Activity Form" or "Unusual Activity Form" for their front line employees. We have to go back to bankers at times and have them contact their customers regarding certain activity that has triggered through our AML system. Many times, we believe it is activity the bankers should have noticed at the time of the transaction, and alerted us to it. We do have quite a few bankers who will contact us with what they think was suspicious activity or unusual behavior, which is great. But many don't seem to understand or they feel that they are prying by asking a customer "source of funds" or other questions. I've heard of some banks that use a form for the banker to fill out, kind of a checklist. We have annual BSA training and we also have semi-annual meetings to go over BSA and KYC, but maybe some kind of Suspicious Activity Form would be helpful. If anyone has something they would be willing to share, that would be great.
Thanks for the help.

We used to have a form, but the form brought on a lot of problems. We found that the front line staff didn't like to complete and the customers got upset when a form was being completed. IA then wrote us up for not using it.

Front line staff has commented that they find it easier to get information from customers about activity when they have a simple conversation. The BSA Department is then emailed by the person who spoke to the customer and they provide a detailed description of the conversation had with the customer. This has worked out well for us.

Whether they feel like they are "prying" is irrelevant. We have written BSA responsibilities into all front line staff job descriptions. They know well ahead of time what is expected of them. PE's and raises can be downgraded based their performance.

kal8 - send me a PM with your email & I'll share mine with you.

We use it as an "option" to use. It gives them an idea what I'm looking for. It's not to be completed in front of the customer at all.

Most employees choose to send me an email, which is also fine.

We thought the form might cause more issues,which is why we've never used one. But, we're looking for a way for the bankers to really "get it"! To get how important it is they ask questions and email or call us with ANY suspicious activity. It seems that right after training, we'll get a lot of emails and calls and of course that dies down. If a Branch Manager doesn't feel comfortable asking their customer questions, how is that going to flow down to their employees?? ACBbank, I agree it should be reflected in raises! That is not happening here...yet. I understand how it can be very difficult to have certain conversations with customers, any seminars or webinars on that subject!?
I want to help our front line, it seems like the importance of BSA only gets through to some, unfortunately.

kal8 - I just sent you a PM for your form. We were just having this discussion yesterday. When a brand new customer is opening an account with >$20,000 in cash, a question or two should be in order.

Exactly! We had a foreign customer open an account, had a passport, no employer, and $25k cash. Nobody thought to ask any questions about that. And we do a lot of training! We really try to emphasize how important BSA is.

kal8 send me a pm with your email and I will be glad to send you what we use. Our form also is to be completed by frontline staff but not with the customer present. This is to alert me of any suspicious activity they may detect. This takes the responsibility out of the hands of the frontline staff and I review whether further action should be taken.

This also helps with the regulators in that they know that this shows that there is communication taking place with staff members and the BSA area.

We used a system similar to CrashDavis's bank. There were often times when I had to interview the teller or CSR who sent the form to get a better sense of what was "hinky" about the customer activity than the form could convey. But I counted each form received as a little victory that at least there was recognition that reporting this stuff was important. And the interviews, often out at the branch, was a welcome break from my office where I got to reconnect with staff that didn't often get out my way.

The slickest I've seen is an e-mail template called a "Suspicious Incident Report" which employees were required to complete and click "send." It automatically went to two different BSA specialists.

They did not do it while the customer was there...

This is what we've set up. The form asks much of the information that's needed for a SAR and when the employee hits "send," it goes to the five members of our SAR Committee. One member of the Committee "accepts" the form and brings it to the next meeting for discussion.

If you want the front line officers to get it. Discuss in detail the concept of “Willful Blindness” and how they can go to jail; it worked for me (I am told that one Branch Manager got so scared, after my training, they asked for a transfer out of the retail division)

Our retail manager is using the new BSA_SAR form which lists the different types of suspicious activity to help the front line in particular understand what may be considered unusual activity.