I attended Ken Golliher's seminar yesterday in Tulsa, it was very informative. I understood him to say that even if we don't do international transactions at this time, that he would still advise us to address Section 311 (Special Measures) of the USA PATRIOT Act in our policy/procedures. I was hoping someone
could weigh in on this for me.
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?
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?