BSA Training To Be Suspicious or Not?

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Filing suspicious Activity Reports goes against the grain - most of the time. We tend to be very uncomfortable with the idea of ratting on someone behind their back. And we also tend to be uncomfortable with the idea of deciding that something is in fact suspicious. The doubts about the correctness of our suspicions also feed our concern about being benevolent. We don't want to be the person that got an innocent customer into a whole lot of trouble. So our bank staff tends to overlook suspicious situations and we may not be reporting all that we should.

The Bank Secrecy Act Advisory Group recently published its review of SAR activity. The report includes some interesting information that may be useful in your training programs. There is nothing like a dose of reality to liven up a session. Knowing that other banks have identified problems also motivates people to pay more attention.

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Try including the following information in your training:
The most common reason for filing a SAR is money laundering or structuring.

The second most common reason for filing a SAR is check fraud.

Other topics include counterfeit checks, embezzlement, credit card fraud, and false statements.

There are some things every employee should know about SARs. Make sure you discuss the points below.

What Every Employee Should Know About SARs

First, filing an SAR is not the equivalent of calling up the FBI and telling them to investigate a customer. Filing an SAR simply puts information about the individual and the transaction(s) into a database.
Law enforcement doesn't pursue every suspicious report. They look for patterns. If our customer is actually innocent, then the report will probably never be noticed. It will be about as noticeable as white noise in the system. But if our customer is part of a bigger undertaking, our SAR may be a critical piece of evidence.
Not filing an SAR when we have a suspicion could later look like we were aiding and abetting the bad guys. Hindsight tends to see things differently.
What is suspicious? Anything that is not normal or clearly related to the consumer's reasonable banking transactions.
Cover these points about completing SARs. A correctly completed SAR can make a huge difference; an incorrectly completed SAR can end up as junk.
Provide a clear and detailed description of the activity and the suspect. Assume the reader knows nothing. But remember, this isn't a novel. Be concise.
Never ever attach supporting documents. Those stay in the bank and we keep them for a long, long time - five years minimum.
Use a standard format to identify the bank or banking organization. This makes it easier for an investigator to follow up with us.
Know who the primary federal regulator for our bank is and name that regulator on the form.
Suspected dollar amounts should be stated in round numbers. This is not the time to try to balance. Ignore the pennies! In fact, ignore numbers smaller than a thousand. Round to the nearest big number.
Send the report to the IRS' Detroit Computing Center.
Filing SARs helps to keep our community safe. Tell everyone to go home and hug a family member!