08/04/2003
As it relates to IT examinations, what are the top "hot buttons" for regulators?
06/16/2003
We are working on our AML procedures and training and are trying to find examples of how someone would launder money by using a loan. We have come up with buying a CD with a small amount of cash, pledging it on a loan, and using it to pay off the loan. What other examples can you give?
06/02/2003
We are a fairly new, small, community bank. We would like guidance on what to include in our annually required security report to the board of directors.
03/03/2003
What banking positions are required a national bank's board of directors required to appoint? I know that certain regulations require, for example, the appointment of CRA, BSA and Security Officers.
12/01/2002
The American Bankers Association and the American Bar Association recently held their 14th annual Money Laundering Enforcement Seminar.
07/01/2002
I currently report to the Senior Manager in charge of Technology and Operations. There is discussion about me reporting to the Senior Retail Banking Manager. I am looking for some resources that provide a discussion about the area of the bank the security officer position should fall within.
05/20/2002
Recently someone brought me a copy of the discussion held on BankersOnline regarding the reporting of SARs to the board of directors. I was a bit surprised at the stern reaction from the panel and I am a bit puzzled by it. The law states that an institution cannot notify the individual suspected of the suspicious activity that a report is being filed, but it does not state anything about reporting to the board. Our practice has always been to file the SAR immediately upon completion and then at the next regularly held BOD meeting a copy is put in each board packet. If there is something we are missing we sure would like to know about it because that is three of you that appear to believe there is something wrong with our process.
05/06/2002
I know I have to let the Board of Directors know when a SAR is filed. I was told all I can tell them is that one is being filed. Is this correct... how does it get in the minutes and what does it have to state?
04/01/2002
Are banks required to have independent auditing of their Bank Secrecy Policy and files? If so, what should the audit consist of?
04/01/2002
I recently read your response <a href="http://www.bankersonline.com/articles/v06n03/v06n03a17.html">Reporting SARs to the Board of Directory</a>. Is there some legal authority which I can show our Boarch of Director's secretary? Our Board has, in the past, seen SARs and decided on whether or not to file before they were sent in. What is your take on this? As compliance officer, I think they should not be informed until after the SAR has been submitted.