If we have reason to suspect that one of our bank staff members may be involved in internal fraud, who should begin the internal investigation – human resources, internal audit, legal or security?
Should Internal Audit have access to the Bank's Security Cameras on
a full time basis?
If the bank has a whistle blower line, who should be
responsible for investigating the complaints?
Is there a procedure that Reg E says we must follow to investigate a claim?
I often see references to "enforcement actions" taken against institutions by examining agencies. What are these actions and why are they levied?
During my most recent BSA/AML report to the board, there was discussion regarding the number of cases/investigations we conduct versus the number of those that actually result in a SAR filing. The board asked if I could compare our percentage of filings with other banks. I'm not certain that there is a good way to do this comparison due to the many variables in each bank and how they address those variables. Do you have any advice how to properly address the question?
I participated in a recent seminar where BOL Guru Dana Turner was the presenter. He mentioned that there might be a conflict of interest if the bank's Security Officer was also a director. I am in that position and I have discussed this with the Board/Executive Committee and was told today that they had talked with our bonding company and were told this was not an issue. What is the rational for ensuring that our Security Officer should be an employee, rather than a director?
I was wondering how other banks handle criminal background checks for interns. For new hires, we fingerprint them and submit them through the ABA / FBI program, but by the time I get the clearance back, the interns are usually gone. Any opinions or advise would be greatly appreciated.
Is there a certification course available for financial institution security officers?
This section of The SAR Activity Review affords law enforcement agencies the opportunity to summarize investigations where Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs) an
by: Scott Daugherty, Assistant General Counsel, Texas Bankers Association