11/09/2009
When filing a SAR for check kiting, part of our process is to set an alert on our teller system that directs tellers not to accept deposits from the suspect customer that include checks the customer has drawn on accounts in other banks. We do this instead of closing the account. Does anyone else do this? If so, what do you tell your customer? I know we cannot say anything about the SAR or that we have knowledge they are kiting, so what else can we actually tell them for an explanation?
08/17/2009
Do tellers need to run an OFAC check on a non-customer that comes in to cash a check on a customer’s account? The checks range anywhere from $5.00 to over $2500.00.
12/08/2008
If funds transferred from the vault for use during the day as well as funds remitted by the tellers are kept in a safe outside the main vault, is it a good practice for the supervisor to have sole custody of both keys of the safe? Secondly, if tellers have loose notes in their mallets at the end of the day (representing the float in their tills) which are not double counted by the supervisor, is it good practice for a bank to keep a duplicate of the key to the mallet which can be used in case of an absence of one of the tellers? Would this entail a risk of accountability in case of a cash shortage when the bank opens the teller's mallet in his or her absence?
09/22/2008
What position (head teller, loan officer, etc.) of the bank would be the best candidate for our BSA officer? Would it be our compliance officer?
08/08/2008
During a healthcare fraud investigation, a routine search of BSA records revealed CTRs and SARs on one of the subjects.
06/30/2008
I understand that some banks complete SARs for what is commonly referred to as forced balancing by tellers. This activity is also referred to as misrepresenting cash totals. Is a SAR required when a teller misrepresents her cash totals in order to force her cash to balance against the teller system? There are many reasons a teller might do this, one of which might be to conceal a theft. Let's say, for instance, you are investigating a mysterious disappearance of $3,000 from a teller's cash fund that was discovered on a surprise cash count. During an interview the teller denies stealing the cash, but acknowledges having forced balanced to temporarily conceal the shortage because she was in a hurry to leave the branch for the day? Although the circumstances of the shortage might indicate the teller possibly stole the cash, would a SAR be required due to the teller's acknowledgment of forced balancing?
06/23/2008
Do our Systems Administration IT guys and human resource people need to be trained on BSA? I am the new BSA Officer for a Savings Bank and the above have had no BSA training.
03/10/2008
Our tellers keep their purses at their teller stations. I was always taught that they should keep them with their coats in the lounge. Is there any law that can give some guidance on this?
01/07/2008
If a customer claims that two bills they received from the bank were counterfeit, what are the proper procedures for handling this situation and reporting it accordingly?
06/04/2007
One of our branches has a customer (a builder) writing large checks to their employees on a weekly basis ($5k-$7k). The builder comes in with the employee to cash the check. The employee endorses first, then the builder endorses and cashes the check. The builder is a known customer, so the tellers do not get identification on him and since he endorses after the payee they are not getting the payee's identification. They are, however, checking the payee/employee against OFAC. Bank policy states that we check OFAC on all non-customer payees over $1000 and record identification on non-customers and payees over $3000. I am getting a match on two of the three employees. I am 90% sure that it is a false positive, but I cannot confirm or deny it is a valid hit unless I can compare their identification information to the hit. The branches administrator was notified that the branch is not following bank policy and that identification needs to be obtained on the payees. The branch defends their actions stating that, technically, they are not making an exception since the employee and builder are presenting on-us checks we are able to verify funds and also that the last endorser is vouching for the non-customer. I understand their concern because it is technically true, but as the Compliance Officer I also understand that, per OFAC, banks must block transactions that are by or on behalf of a blocked individual or entity. If this branch continues to willfully ignore the intent of the customer, which is to give money to this employee, we will end up with severe penalties if the payee is found to be a blocked individual. This is a risk I would rather the bank not take. Can you shed some light on the subject?