BSA Finding

Posted By: Anonymous

BSA Finding - 02/01/05 02:42 PM

As an internal auditor, if you identify a transaction that you see as structuring (long time customer takes out $30,000 over a period of 4 days. 3 transactions in the high $9,000's). How do you handle the difference of opinion? BSA Officer does not believe it is SAR worthy. Seems to me we have filed SAR's for similar transactions in the past.
Posted By: rlcarey

Re: BSA Finding - 02/01/05 02:45 PM

You document your recommendations and report to the board and the board and management decides whether to act. That's about all you can do.
Posted By: CSpellman

Re: BSA Finding - 02/01/05 02:56 PM

I'd ask the BSA Officer why it wasn't before proceeding. Rather than state a SAR should have been filed, maybe the issue was that the transactions weren't identified and aggregated. Therefore the bank doesn't have a program for monitoring such transactions. Look at the bigger picture rather than (maybe) one instance.
Posted By: Anonymous

Re: BSA Finding - 02/01/05 03:12 PM

The transaction was identified by the BSA department and they performed monitoring of the account. No other such activity was noted, so he stated that he believed it wasn't SAR worthy. No other explanation that that.
Posted By: Anonymous

Re: BSA Finding - 02/01/05 08:50 PM

Am I off base on this one?
Posted By: Jokerman

Re: BSA Finding - 02/01/05 08:57 PM

What explanation did they obtain from the customer that caused them to conclude the SAR was not warranted? If, as I would expect, the answer is "none," I would include a finding recommending the adoption of a (or adherence to an already adopted) policy requiring documentation of the SAR decision process.

My advice is to stay away from arguing about individual decisions - look at the process: is it reasonable? does it exist at all?
Posted By: Anonymous

Re: BSA Finding - 02/01/05 09:16 PM

I think thats sound advice. Thanks