We have a procedure to review unusual activity in employee's accounts on a regular basis. In addition, if we have a suspicion regarding a teller, we have reviewed account activity for that teller. Are there any privacy rules which would restrict our ability to review our employee's account information? Also, is there any consent required by the employee when they begin employment?
Real Estate Industry ? Sales and Management SARS
General Instructions for Completing the SAR Form
A verified match with an entity on an OFAC list that involves funds in an amount above the applicable SAR filing threshold should trigger a SAR filing requirement.
We have software that can be used to run our customer base against not only the OFAC list, but also a more expansive list. The name list that the software contains in addition to the OFAC list, is an FBI list. My question is this, is the bank required, by any law/regulation/statute, to review any matches other than OFAC list matches? The matches we have appear to be simply common name matches, but obviously I don't want to be out of compliance.
Forgive your enemies, but never forget their names (John F. Kennedy)
Under the USA PATRIOT Act regulations and upcoming CIP, do we need to have photocopies of the driver's license and/or social security numbers for beneficiaries on a Totten Trust? In most cases, we never see the beneficiaries, as they are not signers on the account. Also, do we have to check them on OFAC?
I'm looking for a list of countries, beyond those on the OFAC list, that would fit the definition of "tax haven" or other countries that should be monitored for suspicious wire transfer activity.
What security/liability concerns should a bank have when an employee has a spouse/friend/associate on the terrorist watch list?