12/01/2008
Do you know of a computer program that can detect kiting transactions?
11/24/2008
Our regulators have requested that our bank more clearly define and document its credit policies. What should be included?
11/24/2008
Our bank is affiliated with a holding company and each bank is an independent bank. We have a bank agency contract which allows our customers to conduct transactions at any of the sister banks. Bank A's customer makes deposits at bank B. After meeting all the exemption requirements, bank A filed an exemption for this customer. Since bank B processes the deposits over $10,000, should they continue filing CTRs for this customer even though the bank where the account is housed exempted the customer or does the exemption apply to bank B, too?
11/17/2008
On a deposit, do we have to file a CTR report on the people standing next to the depositor or only the person holding the cash? We usually see this situation when families travel to the U.S. visiting from abroad and bring with them large amounts of cash that need reporting. At times we get into the dilemma of who needs to be reported, the whole family or just the person standing at the teller window or the people who obviously are carrying the money.
11/10/2008
What is the time frame for SAR reporting on a check kiting case? If the check kite has been going on for a year or more should we report all of the activity or only the recent activity that may pose a financial risk to the bank?
09/22/2008
Question: We know that there is overlap between Red Flags and BSA/AML but what are the common functions?
08/08/2008
Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR): Reading With Context By Regina Stone16
08/08/2008
FinCEN is committed to providing quality written feedback to industries affected by new or amended regulations.
08/08/2008
Following a large increase in depository institution SAR filings on mortgage loan fraud, FinCEN issued a report in November 2006 describing trends and patterns shown in SARs reporting suspected mor
06/30/2008
I understand that some banks complete SARs for what is commonly referred to as forced balancing by tellers. This activity is also referred to as misrepresenting cash totals. Is a SAR required when a teller misrepresents her cash totals in order to force her cash to balance against the teller system? There are many reasons a teller might do this, one of which might be to conceal a theft. Let's say, for instance, you are investigating a mysterious disappearance of $3,000 from a teller's cash fund that was discovered on a surprise cash count. During an interview the teller denies stealing the cash, but acknowledges having forced balanced to temporarily conceal the shortage because she was in a hurry to leave the branch for the day? Although the circumstances of the shortage might indicate the teller possibly stole the cash, would a SAR be required due to the teller's acknowledgment of forced balancing?