Introduction

What banks are required to do:

  • Establish effective BSA compliance programs
  • Establish effective customer due diligence systems and monitoring programs
  • Screen against Office of Foreign Assets Control (OFAC) and other government lists
  • Establish an effective suspicious activity monitoring and reporting process
  • Develop risk-based anti-money laundering programs

Suspicious Activity Report (SAR) is a document that financial institutions, and those associated with their business, must file with the Financial Crimes Enforcement Network (FinCEN) whenever there is a suspected case of money laundering or fraud. These reports are tools to help monitor any activity within finance-related industries that is deemed out of the ordinary, a precursor of illegal activity, or might threaten public safety.

Suspicious activity reports are a tool provided by the Bank Secrecy Act (BSA) of 1970. Originally called a "criminal referral form" the SAR became the standard form to report suspicious activity in 1996. Mainly used to help financial institutions detect and report known or suspected violations, the USA Patriot Act expanded SAR requirements to help combat domestic and global terrorism. Whether financial or otherwise, SARs enable law enforcement agencies to uncover and prosecute significant money laundering, criminal financial schemes, and other illegal endeavors. SARs give governments an opportunity to spot and analyze emerging trends and patterns across a broad spectrum of personal and organized crimes. With this knowledge, they can anticipate and counteract fraudulent and criminal behavior before it gains a foothold.

Other bank obligations:

  • Keep records of cash purchases of negotiable instruments,
  • File reports of cash transactions exceeding $10,000 (daily aggregate amount), and
  • Report suspicious activity that might signal criminal activity (e.g., money laundering, tax evasion)

Areas Covered In The Webinar

  • What is the Bank Secrecy Act?
  • What is the rationale and purpose of the BSA?
  • What does the BSA require banks to do?
  • What is a Suspicious Activity Report?
  • When must a SAR be filed?
  • What should be covered in a SAR?
  • What are the consequences for banks that fail to comply?

Why should you attend?

Criminals have long used money-laundering schemes to conceal or "clean" the source of fraudulently obtained or stolen funds. Money laundering poses significant risks to the safety and soundness of the U.S. financial industry. With the advent of terrorists who employ money-laundering techniques to fund their operations, the risk expands to encompass the safety and security of the nation. Through sound operations, banks play an important role in helping investigative and regulatory agencies identify money-laundering entities and take appropriate action.

Who Will Benefit

  • Banking executives
  • Branch managers
  • BSA officers

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Dr. Jim Castagnera holds an M.A. in Journalism from Kent State University, and a J.D. and Ph.D. (American Studies) from Case Western Reserve University. He worked 10 years as a labor, employment, and Know More

Dr. James Castagnera, Esq.