Form to Report Suspicious Activity to BSA Officer

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Question:

An examiner (FDIC) found that we should have a formal referral system for reporting what is suspected to be suspicious activity to me, the BSA Officer. She suggested that I create a form available to all employees to be completed by any employee who sees what he or she considers suspicious activity. Does such a form exist and if so, where can I find it? If not, what information would you think I need to include in the form?

Answer:

Answer by Randy Carey:A sample of such a form can be found here.

Answer:

Answer by John Burnett:Some of the discussion at BOL's recent BSA/AML Conference (Top Gun) involved this sort of referral to the SAR-filing responsibility center and most often the BSA Officer. The sample form is a good start, but more important than the form is the process. You should meet with representatives of all of the bank's functional departments and lines of business to create a policy and procedure for referring all suspicious activity to your reporting center. You can use the 2004 AmSouth civil money penalty case as a starting point for discussion, since so much of it involved that bank's failure to have an adequate internal reporting mechanism. Any comments in your most recent exam report or examiner recommendations can prove helpful, as well. Finally, consider whether your bank should provide a mechanism for anonymous referrals for those cases in which an employee might consider a report an employment risk. Such might be the case if reporting suspicions about a co-worker's or manager's activities.

First published on BankersOnline.com 3/16/09