BSA - Practice Makes Perfect

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by Lois Kohn

You can explain when a CTR or SAR must be filed under the Bank Secrecy Act, but it can be much more effective to teach the requirements by example. Simulate various transactions and have the tellers decide if there are any filing requirements.

Here's how I did it: I used a copier to make some copies that looked like $100 bills. (Editor's note: Don't make them too real! You don't want to get busted for counterfeiting!) I then cut the copies down to size. I used newspaper in the same size as the fake $100s to make teller-straps of the "cash" with a $100 on top of each strap.

I began the training by explaining Bank Secrecy Act requirements. I then selected one of the attending tellers in the >
I then gave another teller an envelope with $7,000 in strapped fake money. I asked her if she would file a CTR for this. The answer was supposed to be no.

Then I handed another teller an envelope with $8,000 in "cash" and told her it was from the same customer who brought in the $7,000 cash the day before and I asked if either a CTR or SAR should be filed. The answer in some sessions was yes, some no. The point I was getting to was at what point do you get suspicious and file a Suspicious Activity Report?

I had a third envelope ready, depending on the response to the second envelope. During the envelope discussion, we talked about what if these transactions were at different points during the same day. What if one was in person and one came in through night deposit? What if they were two or three days back to back? How about once a week? What about the occupation of the person making the deposits? This forced everyone to get involved in the discussions. I think I had about four different discussions with different groups of money.

Lois Kohn
Lois Kohn has a Bachelor of Science in Business Administration from Samford University and is a Graduate of the ABA National Compliance School. She has 30 years in the banking industry, 20 as Compliance Officer for Colonial Bank (Birmingham, Alabama). Lois has conducted frequent banking seminars for bank employees and others, and was named Outstanding Instructor for the Birmingham A.I.B. Chapter (1998). In June, 2000, she moved to Dallas, Texas where she is currently Corporate Compliance Specialist with Colonial Bank.

First published on BankersOnline.com 8/27/01