02/08/2010
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?
01/18/2010
Whenever we file a SAR for check kiting, we place a message on the customer's screen, so we will not accept checks from the other bank involved. We do this instead of closing the account. Does anyone else do this? If so, what do you tell your customer? I know we cannot say anything about the SAR or that we have knowledge they are kiting, so what else can we actually tell them for an explanation?
01/11/2010
Do you have any suggestions for a letter to be sent to a customer because we are closing his account due to irregularities? We are closing a customer’s account because we are filing a SAR.
12/07/2009
Are we required to file a CTR if a husband and wife come into the CU together and each withdraws $10,000.00 from their own accounts?
11/23/2009
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?
11/09/2009
We have a customer who recently requested a wire transfer that made us very nervous. When we began asking the necessary questions, the customer became irate and threatened calling his attorney. The wire was going out of the country. Can we refuse to process a wire transfer or do we go ahead and process and follow up with a SAR?
11/09/2009
When filing a SAR for check kiting, part of our process is to set an alert on our teller system that directs tellers not to accept deposits from the suspect customer that include checks the customer has drawn on accounts in other banks. We do this instead of closing the account. Does anyone else do this? If so, what do you tell your customer? I know we cannot say anything about the SAR or that we have knowledge they are kiting, so what else can we actually tell them for an explanation?
11/01/2009
Prosecutors used information directly derived from BSA records to help convict a repeat drug trafficker in Federal court.
11/01/2009
In an innovative use of money laundering statutes, a State successfully prosecuted a defendant for violations of the Federal Bank Secrecy Act.
10/09/2009
Inquiries Received by FinCEN?s Regulatory Helpline By FinCEN?s Office of Outreach Resources