What Do Other Bankers Do?

And yet another idea comes out from the Florida bankers. During a seminar covering compliance and regulations, Michelle Casale from the First National Bank and Trust of Treasure Coast shared with us how suspicious transactions were being handled in her shop.

They were hesitant about making the teller responsible for decisions on filing suspicious transactions. So they put together an in-house form that anyone in the office can fill out and forward to the Security Officer. The person who reports the activity keeps one copy. When the other two are received by the security department, they initial and return one copy to the sender, indicating receipt, and keep one copy for follow-up investigation.

The form has been expanded in another institution to report any policy/happening/transaction/suspicion. In this case, the whole form can be sent to the security or audit department, anonymously. We have reproduced the format here that is being used in Florida. You are welcome to copy it.

SUSPICIOUS TRANSACTION
To be completed when suspicious activity or inquiries have occurred and transactions have NOT been processed to warrant a Currency Transaction Report (Form 4789). Make two copies of your original. Date of Occurrence:
Time of Day:
Teller Name & #:
Office:
Customer Name:
Account Number:
Nature of Suspicious Activity:
Other Comments:
Initials:
Prepared by: ________
Received by:_________Date Received:__________
Distribution of copies:
Original-Send to Security Officer
1st copy-Send to Security Officer
2nd copy-Retain until Security Officer sends first copy back to you as confirmation of receipt.

NOTE: Upon return of 1st copy, initial it and forward it to your compliance officer. File the second copy in office records.

Copyright © 1991 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 2, No. 8, 10/91