We were robbed recently, and as the BSA Officer, I am not sure what forms/reports need to be filed and where they need to be filed. I would appreciate any help. There is no Security Officer to help me.
Some banks in our area have just adopted a "no hat, no hoodie" policy. We are considering it as well. What one thing can I do to convince the board and management we need this?
We have opening procedures for each branch. On occasion, an executive will come in early and completely ignore the procedures we have in place. This leads other employees to disregard them as well. What can I do to make this easier on everyone?
Can we give a customer a photo from the bank's surveillance of a person who committed fraud against him?
Do we need to CIP and OFAC non-customers if we sell them money orders?
I am filing a SAR for suspected money laundering. Our policy states that upper management must decide whether to keep the account open after a SAR is filed. I've contemplated turning the investigation over to our local FBI office in order to escalate the investigation, so that management can make a sound decision about the fate of the account. Our policy also states that requests for SAR information from law enforcement will be denied without a subpoena. Do I need a subpoena in order to release the SAR information to the FBI if I am initiating the investigation? If I turn this over to the FBI, should I only provide the supporting documentation or should I provide the SAR and my documentation?
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?
Is there a certification course available for financial institution security officers?
I work in bank fraud cases. We have a case management system in which we input all of our fraud cases (forgeries, counterfeit checks, unauthorized check card trans,etc...). We are trying to make a determination as to the difference between "recovery" and "loss avoidance" when it comes to bank fraud. Could you please help with a clear understanding on what determines in which category an item would fall?
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