TOPIC: SAR

Free Webinar - Top Priorities for Credit Unions in 2021 and Beyond | Earn 1 CFCS credit and 1.25 CAFP & CRCM credits

Wednesday, May 12, 2021
2:00 PM ET / 1:00 PM CT
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BSA/AML continues to be a priority for the NCUA. With new technological advancements and changing policies, it can be a challenge to sort through and follow the NCUA’s 2021 Supervisory Priorities with the limited resources credit unions have. In this session, Steve Gibbs, CUCE, BSACS, will discuss the proactive measures your credit union can take to reduce risk, protect your members, and manage priorities ahead of your next NCUA examination. 

Join this session to learn:  
  • Best practices to maintaining correct and efficient SAR and CTR filings  
  • Methods to accelerate digitization and utilize automation to reduce risk within your BSA/AML program 
  • Key questions for credit unions to ask to properly evaluate the potential value and risk of serving cannabis-related businesses 
  • How to create a culture of cybersecurity awareness at your institution to keep your credit union and your members safe from new threats 
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    Verafin Users with a SAR Committee

    Employee at a bank ($186MUSA)
    For any FIs that utilize a SAR Committee for decision making (and also use Verafin), what does your process look like? Currently, I create PDFs of the case report and any supporting documentation and then send it through ProSign for a signature if they agree to what I'm requesting (file a SAR, do not file, continue to monitor, etc.). I would like to transition our SAR Committee to logging into Verafin and completing their process and am looking for the most efficient way to do that. I'm thinking just having them add a note with their decision and feedback, but does anyone do something else? 

      What to indicate when completing a SAR

      Manager at a bank ($290MUSA)
      Just discovered a checking account for an Unincorporated Business Trust Organization (UBTO), AKA "Common Law Trust", AKA "Constitutional Trust", AKA "Pure Business Trust", and I am sure that there are a ton more AKA's.

      The account has been closed and we believe a SAR should be filed.  Has anyone ever completed a SAR on one of these type accounts?  When completing items 32 through 38, I really only come across item 38z - Other as an option to indicate.  Basically, the account was used like any normal DDA for the individual's personal use, but the fact that it is an UBTO is causing us to believe we should file.  Since it has been on the books for a LOOONG time, we were also thinking of not indicating an amount involved, as not all the statements are available anymore, but the suspicious activity dates would seem to be from account opening to account closing.

      Anyone have any experience or feedback?  And thank you in advance.  It is just LOVELY what we seem to come across over time.  :)

        Blog | Modernizing SARs: Jim Richard’s revisits the AML Act of 2020.

        Blog
        AML Act of 2020 Progresses SAR Regime
        Renewing the BSA — Part 2

        February 19, 2021 by Jim Richards

        Read the full blog now

        The Anti-Money Laundering Act of 2020 (AMLA) is a major milestone in the history of the BSA — and an important step toward advancing Suspicious Activity Reports (SARs). From provisions to streamline and automate aspects of suspicious activity reporting, to delivering feedback on SAR utility, the AMLA will modernize the SAR regime with important industry implications.

        Read the next installment of Jim Richards’ Renewing the BSA series as he explores how the AMLA will contribute to much needed SAR reform, and why it has never been more important to be engaged and active with peers, trade organizations, and your regulators.

        Read the full blog now

          Patriot Officer

          Employee at a bank ($1.2BUSA)
          Does anyone use Patriot Officer for SAR filing and can tell me where to input information so it populates SAR field 2 (Filing Institution Note to FinCEN)??

            Demonstration | BSA/AML Compliance and Management - Join us Jan 13

            January 13 at 12:30 PM - 01:30 PM EST
            BSA/AML Compliance and Management
            Uncover Suspicious Activity & Strengthen Compliance

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            Today’s landscape of changing regulatory requirements creates enormous pressure for compliance professionals to uncover potential money laundering and stay ahead of suspicious activity. Yet, many financial institutions still rely on legacy systems, broad rules and manual processes to manage daily compliance tasks.

            Join us as we demonstrate how Verafin’s Financial Crime Management platform uses a big data intelligence approach, leveraging artificial intelligence and machine learning to significantly reduce false positives and generate higher quality alerts. You will see how Verafin enhances anti-money laundering efforts with complete BSA/AML functionality to strengthen compliance and enhance your ability to detect, investigate and report potentially suspicious activity.

            Highlights of this software demonstration will include:
            • Risk-rated targeted BSA/AML alerts and scenarios
            • High-Risk Customer Management and end-to-end Customer Due Diligence/Enhanced Due Diligence (CDD/EDD)
            • Alert threshold testing and performance monitoring
            • Integrated Case Management
            • Automated regulatory reporting of SARs and CTRs
            • 314(b) Information Sharing
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              Chargebacks on SARs

              VP at a bank ($2BUSA)
              Hi all, when completing a Suspicious Activity Report on chargebacks and/or unauthorized returns, would you check off any boxes in Section 46 on the SAR report?  Technically, we would not be indicating that the transactions themselves are suspicious, but instead the volume, frequency, and amount of the chargeback/unauths are.  Thoughts?

              Context: TPPP clients that we process payments for who may be in the nutra space and have high volume of returns for fraud/unauthorized.

                Blog | Analysis & Commentary: FinCEN’s Proposed Burden Estimate for Preparing and Filing SARs

                Blog
                Analysis & Commentary: FinCEN’s Proposed Burden Estimate for Preparing and Filing SARs
                May 29, 2020 by Jim Richards

                Read the full blog now

                On May 26, 2020, FinCEN published a ground-breaking Notice — the first requesting private sector feedback on estimating the burden of preparing and filing SARs. 

                With the Agency proposing to capture time and cost across several SAR categories, filing types, process stages and more, financial institutions should provide FinCEN with tangible, publicly available data to improve public- and private-sector decision making. 

                Read our blog from former top banking executive Jim Richards as he provides insights and commentary on this landmark Notice, and learn how institutions can submit input and feedback.

                  SAR - No SAR

                  Employee at a bank ($650MUSA)
                  I'm struggling with determining if a SAR should be filed - Wonder what people would do - Individual account owner with individual cash withdrawals and checks written to husband cashed at teller line. Customer is known to be finishing building a rather large house and paying some items in cash for better pricing which explains activity.  Account owner has also issued checks to husband which he took to his FI all between $9,000 - $9,800.  Would you file for structuring? Do we included the husbands cashing activity as suspicious?10/30 $9,000 cashed check by payee (husband)11/5 $9,500 cash w/d by account owner11/17 $9,800 cashed check by payee (husband)

                    SAR filing requirement for loan issued in 2017

                    Manager at a credit_union ($3.9BUSA)
                    We have a loan that was issued to a customer in 2017. The loan was closed out in 2019 at a loss to our FI. It was just identified last month during a data clean up process that this loan was part of a fraud ring that was reported on in 2019. This loan was not included in the 2019 reporting as it was not linked to the fraud ring at this time. Should we now process a new SAR for this loan? Or is it not necessary since the individual is no longer a customer and we have already filed on the larger fraud ring involved well over 1.5 years ago? Trying to figure out if there is any type of statute of limitations or time constraints when determining if a SAR should be filed or not for old incidents like this one.

                      Free Webinar | The FinCEN Files: What Do They Mean for Your Institution? | Earn 1.25 CAFP, CRCM credits

                      Tuesday, October 27, 2020
                      2:00 PM ET / 1:00 PM CT
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                      The FinCEN Files have shaken compliance professionals to their core since its release in September, with groundbreaking reports of money laundering, corruption, and detail into Suspicious Activity Reports filed by banks. What will this breaking news mean for your financial institution and how will this reshape our current compliance systems? In this session we breakdown the specifics and provide tips on how to ensure your suspicious activity doesn’t go unnoticed by law enforcement.  
                      Join this session to learn:

                      This session is eligible for 1.25 hours CAFP & CRCM
                      Register here 

                        SAR Writing Checklist | Free Download

                        SAR writing and filing is arguably one of the most important responsibilities of BSA professionals. Leverage this SAR Writing Checklist to ensure you have incorporated the key items law enforcement is looking for in a quality SAR.
                        Download this checklist for:
                        • Essential elements to include in each SAR
                        • Key components of a compelling narrative
                        • Other critical details that must be addressed
                        Download here.

                          SARs Made Easy | BAM+ Demo

                          Monday, September 28, 2020
                          3:00 pm ET / 2:00 pm CT
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                          With suspicious activity on the rise, it's imperative for compliance professionals to streamline and optimize their BSA/AML program. In this demo, you will see how BAM+ allows you to organize your alerts with end-to-end case management while reducing false positives for your team. 

                          "To be successful in my role, I need robust software...it makes life much easier when we can work smarter – not harder – with BAM+. BAM+ is the future of BSA/AML software."
                          Mike Foster, Dickinson Financial Corporation

                          Join to learn how our BAM+ solution can help you:
                          • Facilitate SAR filings for both BSA/AML and fraud incidents together in one system
                          • Customize your software to your institution's unique risk profile
                          • Harness and combine data to gain insights and a bigger perspective into your program
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                            Fighting the Good Fight

                            Earlier this month, the Financial Crimes Enforcement Network (FinCEN) put out a cryptic statement regarding the unlawful disclosures of suspicious activity reports (SARs).   According to FinCEN, various media outlets were intending to publish a series of articles based on unlawfully disclosed SARs, as well as other sensitive government documents.  Some of you may have read the Buzzfeed article referenced by FinCEN and may have had the same reaction many of us here at 10-D Security had after reading it – mainly that, as bankers, compliance officers, and auditors, we know and understand the importance of monitoring and reporting on suspicious activity.  We know these reports are filed to support government investigations of money laundering and terrorist financing, as well as other nefarious activity – not to profit off suspect transactions or support bad actors.  We appreciate the sincere responsibility financial institutions take on a daily basis to monitor and report on suspect activity.     With that being said, we thought maybe now would be a good time to remind everyone of the numerous tips, suggestions, and guidance available on FinCEN’s website regarding SAR filings.  From “Avoiding Common Errors in SAR Filings” to “SAR FAQs” to our personal favorite, “Writing Effective SAR Narratives” – there is a treasure-trove of information available to help you perfect your SAR-filing skills just a click away at www.fincen.gov. We also want to take this time to send a huge shout-out to all the Compliance Officers out there … did you know that your special day is just around the corner? September 26 is National Compliance Officer Day!!!  Can I get a woot woot?!?!!!  So, to all you compliance officers, thank you for fighting the good fight.  Your efforts are truly appreciated! 

                              Free Webinar | SAR Writing - Using Purpose and Clarity to Aid Law Enforcement | Earn 1.25 CAFP & CRCM credits, 1 CFCS credit

                              Tuesday, September 22, 2020
                               2:00 PM ET / 1:00 PM CT
                               Register 

                              SAR writing is easier said than done. BSA Officers often ask, “What happens to our SARs once submitted? Is anyone even reading this information? How do I alert law enforcement to COVID-19 related fraud?” In a never-ending sea of SARs filed with FinCEN each year, it is important that your SARs are noticed and read by law enforcement. Learn how to craft a SAR narrative that tells your story and captures the attention of law enforcement while maintaining regulatory requirements.

                              Join this session to learn:
                              • Discover the minimum requirements of information that must be in your SARs
                              • How to write effective and captivating narratives for your audience: law enforcement
                              • Learn the FinCEN SAR narrative requests for COVID-19 related fraud 
                              • Gain confidence in meeting all SAR writing regulatory expectations
                              This session is eligible for 1.25 credits CAFP & CRCM, 1 credit CFCS
                               Register today

                                Software Demo | Abrigo's BAM+ Fraud Solution

                                Thursday, August 27, 2020
                                3:00 pm ET / 2:00 pm CT
                                Register here

                                The coronavirus pandemic has created many vulnerable targets, including the elderly and unemployed, and fraudsters are taking advantage at an alarming rate. Do you have the right systems in place to prevent these attacks from happening at your institution?

                                In this session, we will demonstrate Abrigo's BAM+ Fraud solution which provides institutions with a centralized case management workflow and robust analytics engine to detect, investigate, track, and report on potentially fraudulent activity threatening your institution's reputation and bottom line. 

                                Join to learn how our BAM+ Fraud solution can help you:
                                • Identify fraud across different business lines and transaction types
                                • Facilitate SAR filings for both BSA/AML and fraud incidents together in one system
                                • Import fraud data files directly into BAM+ for scanning and detecting anomalies

                                Save your seat!

                                  Dummies eBook | Suspicious Activity Reporting for Dummies® - Download Now

                                  Dummies eBook
                                  Suspicious Activity Reporting for Dummies®

                                  Download Now

                                  Suspicious Activity Reporting for Dummies® walks you through the process of filling out your SAR accurately and efficiently and offers tips on how to spot and track potential money laundering activities.

                                  Look inside for helpful advice on how to make your AML workflow more efficient, save on costs, and streamline your institution’s monitoring and reporting processes with automated SAR e-filing.

                                  Download Now