01/31/2011
If a Secret Service Agent comes to review information filed in a SAR on a customer, will he need a subpoena?
01/03/2011
A customer visited a branch and requested that his account be closed, and wanted to take $50,000 in cash. The teller inquired as to the reason for the cash. The customer became irate and informed the teller that it was none of her business. The teller informed the customer that the cash would have to be ordered and the matter would have to be discussed with the Security Officer. The customer return a week later to inquire if the cash was ordered, and was told no, and that the officer would get in touch with him. The customer then withdrew the request. Should we consider filing a SAR for an unusual request for cash? A review of the customer's history showed that he had never conducted a cash transaction on the account. The customer also deposited a large check to another financial institution after the request was withdrawn at our institution.
11/15/2010
Is it a requirement of the Bank Protection Act to annually receive board approval for the Reporting of Criminal Acts Policy?
10/18/2010
We have a case of counterfeit US Postal money orders. Do I have to report that to FBI or Secret Service? If so, how? Do I just call them?
09/13/2010
09/06/2010
A customer deposited cash: $6000 one day and $5000 the following day to the same account. Should a CTR be filed since we noticed this trend or should the transactions be ignored since they occurred over a two day period? If we don't file the CTR, are we required to file a SAR?
08/23/2010
Upon verifying the SSN of a new customer's information, it was found to be that of a deceased person. Do we need to fill out a SAR on this?
08/16/2010
We have a member who withdrew cash three weeks in a row, same branch different tellers. The withdrawals weren't over $10,000, but total of withdrawals is $18,000. Can we file a CTR as multiple transaction? The member is retired and was withdrawing some of his retirement funds.
08/16/2010
I work in the BSA Department. My bank was just acquired by another bank and we found a customer of theirs who runs a factoring company under his personal TIN. His activity consists of depositing checks payable to other businesses (in the week period I have access to - databases not merged yet - the checks range from $25 to $12,500) and withdrawing cash (about $250,000/month) to pay his clients. From what I can tell, based on online research, the debtor businesses should be remitting payment directly to the factor, not the original vendor, and the factor should not be dealing in cash in any way. It appears that he may be acting as an unregistered check casher for businesses. How can I determine if this is the case? Do you agree that he should not be depositing third party business checks?
08/02/2010
A customer recently told a teller that he was cashing out most of his account in order to avoid garnishment from a creditor. He also told her he was opening a safe deposit box to keep the money "safe" from the creditor. A CTR was filed, but my gut tells me to file a SAR. Is this correct? If so, what is the reason?