Regarding alerting employees to being suspects of investigations as a result of SAR filings, I know we cannot disclose the existence of the SAR, however, but do we have a duty to inform our employee that an investigation is now focused upon them which would activate the need for legal representation, or would the safe harbor also apply in this case?
What procedures should be followed in the case of missing travelers checks? We have our internal auditors on the case now. What steps should the compliance officer take and is there anything he/she needs to do or will the security officer have most of the responsibility?
The capability of searches by law enforcement agencies through the requests sent to financial institutions by FinCEN is not quite working out the way it was supposed to.
SAR Initiates Investigation of Illegal Money Transfers to Iran
Due to the rise in check fraud and identity theft, we are receiving more and more requests for customer and account information from local law enforcement. These investigations may or may not involve a bank loss, and some of the investigations are the result of a customer's police report. Do you know of clear-cut guidelines when we can provide the requested information or when a subpoena or search warrant is required? We want to help stop crime, but I wish not to contact outside counsel every time a law enforcement request comes in.
The American Bankers Association and the American Bar Association recently held their 14th annual Money Laundering Enforcement Seminar.
I am the Internal Auditor at a small bank. We had $3,000 stolen from a teller's drawer by another employee. I think I know who took the money because I have collected supporting evidence. All of the evidence is circumstantial. What are my options with this teller? I am new to this position and have had training in finding fraud, but not in dealing with it. I do not want to violate her rights but would like to question her. Please advise.
Between November 2000 and January 2001, SARs were filed by two (2) banks indicating accounts controlled by Victor Alberto Venero-Garrido had received large and suspicious deposits totaling over $22
By A.H. "Buck" Shuller, CFE, LPI
Recently someone brought me a copy of the discussion held on BankersOnline regarding the reporting of SARs to the board of directors. I was a bit surprised at the stern reaction from the panel and I am a bit puzzled by it. The law states that an institution cannot notify the individual suspected of the suspicious activity that a report is being filed, but it does not state anything about reporting to the board. Our practice has always been to file the SAR immediately upon completion and then at the next regularly held BOD meeting a copy is put in each board packet. If there is something we are missing we sure would like to know about it because that is three of you that appear to believe there is something wrong with our process.