When it comes to BSA Compliance - If a member/customer withdraws $10K each day for 3 consecutive days, in what circumstance would one not think this is a reportable suspicious activity?
I was offered a $25 bribe not to file a CTR. What should I do when this happens?
Our Compliance Division has taken the position of not letting us know if a SAR has been filed on a matter that we refer to them for a potential SAR filing. Is there some sort of regulatory requirement prohibiting the confirmation of a SAR filing?
I was told by an examiner a few years ago that a bank is not required to report a SAR to its Board of Directors if the SAR involves a member of the Board. That provides protection for the person filing the SAR. Is that correct? If yes, where can I find that information? Thank you.
When the owner of an ATM resides in a state that requires the ATM be registered refuses to register that ATM; do you file a SAR on that customer for failure to provide documentation? If a SAR is required, does the continuous SAR filing rule apply until the customer complies?
Our recent examiner said we must work up a potential SAR report for summonses & subpoenas. Does this apply if the subpoena is on a former customer (currently closed)?
Can SAR information be given to internal auditors? I have always been told to keep these strictly confidential.
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 Does aggregated total mean the amount deposited and the amount withdrawn as one total?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?
Filings on Mortgage Brokers
SAR Filing Leads to Embargo Investigation