Answer by John Burnett:
This seems tailor-made for security, rather than compliance. Of course, if the dollar amounts are significant enough or if an employee is implicated in the investigation, your security officer may consult with the compliance officer about SAR filing, if appropriate under your bank's procedures.
Answer by Dana Turner:
There are several threads available that address how investigations are/should be performed. A brief recap includes:
-The Security Department should conduct ALL investigations, initial and follow-up, and the Security Officer should delegate and coordinate the initial investigation to the manager of the department that experienced the event/suffered the loss;
-The Audit Department should act as the Security Department's investigative partner, gathering and securing evidence and writing the investigative report;
-The Compliance Department should ensure that all of the institution's policies and procedures were followed, and that no laws, rules or other regulations were violated; and-The Human Resources Department should become involved if an employee is believed to be responsible for the event/offense -- initially as the Security Officer's investigative partner and later as the institution's representative.
First published on BankersOnline.com 07/07/03