I am the security officer of my bank. We had a problem concerning large cash shortages at one of our branches. When I asked operations to have one person sent to me at a time they refused. They told me they didn’t have time to play games because they were short staffed. I would have to go to the branch to question staff members.
While attending a class on interviews the instructor kept discussing the baseline. The instructor never defined what is a baseline?
While questioning a person we suspected of conducting an internal fraud I noticed he kept picking at his clothing. I found it to be very hard to question him as this behavior persisted.
If a financial institution discovers a crime or fraud and wants to notify law enforcement, what if anything is needed before records/documents are turned over to help with the investigation?
Question: Can BSA/AML programs satisfy Red Flags compliance?
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?
Update: Auditing the AML Program ? What?s New?
By Alan S. Abel, CPA, representing the American Institute of Certified Public Accountants to the Bank Secrecy Act Advisory Group
Who is the customer when an account is opened by a power-of-attorney. I have read over the answer to the question posted under CIP titled <a href="http://www.bankersonline.com/security/guru2008/gurus_sec022508c.html">"POA CIP Requirements"</a>, and also Section 103.121(a) (3) Q and A outlined in the regulation. What is the definition of "legal capacity"? I am in the process of updating the CIP section of our Anti-Money Laundering Policy and I need to address this issue. A POA comes in and opens a checking account for an individual that is incarcerated. The POA document provides for the POA to open accounts for that person. Since the individual is in jail, does he or she lack legal capacity?
I have some questions relating to penalties and prison terms for violations. What is the maximum fine and maximum prison sentence for willful BSA violation? What is the maximum fine and maximum prison sentence for violating anti-money laundering statutes? What is the fine for negligent CTR reporting and the fine for willful violation of CTR reporting? I have looked on FinCEN, checked the IRS and your website for a definitive answer and can not seem to find one.
Date of ?Initial Detection? and the 30-Day SAR Clock By FinCEN Office of Outreach Resources