I am unsure what to enter when completing the dollar amount involved on a SAR. Does aggregated total mean the amount deposited and the amount withdrawn as one total? An example is a kiting scheme, would I enter the amount of checks deposited from the other bank or the amount of checks written to the other bank or both?
It is my understanding that a ninety day review is required to establish a true kiting pattern. Is this a BSA or industry requirement?
We have a kiting scenario come to life, and I want to make sure I am covering all my bases. A SAR will be filed. What law enforcement should be contacted: FBI or local? This is a very large amount, do I need to notify our primary regulator? If so, how soon?
Would there be a fine to a financial institution for not filing a SAR on an employee for check kiting?
Whenever we file a SAR for check kiting, we place a message on the customer's screen, so we will not accept checks from the other bank involved. We do this instead of closing the account. Does anyone else do this? If so, what do you tell your customer? I know we cannot say anything about the SAR or that we have knowledge they are kiting, so what else can we actually tell them for an explanation?
We have a customer who has been kiting very obviously for the past two years. I have filed a SAR on them every quarter for the past two years. I have fianlly convinced management to close his account. The last SAR was filed in July, and the account was closed in October. There doesn't appear to be any kiting activity since my previous filing, but should I still file the SAR because we finally closed the account, and a SAR has been filed every quarter for the past two years?
When filing a SAR for check kiting, part of our process is to set an alert on our teller system that directs tellers not to accept deposits from the suspect customer that include checks the customer has drawn on accounts in other banks. We do this instead of closing the account. Does anyone else do this? If so, what do you tell your customer? I know we cannot say anything about the SAR or that we have knowledge they are kiting, so what else can we actually tell them for an explanation?
How much information can a financial institution share with another financial institution that is under the 314(b)?
Do we file a SAR for suspected check kiting where there was no loss, and we believe the person actually was moving "good" money in order to increase balances to receive additional interest?
Among credit risk, market risk and operational risk, developing a good operational risk management program seems to be the most challenging. Can't our existing compliance processes (e.g., AML, Red Flags, GLBA, etc.) contribute to operational risk management?