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Thu, Jul 29, 2010


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  Suspicious Activity Reporting: How, when, why  
(Presented By: Ken Golliher)

"Suspicious activity reporting forms the cornerstone of the BSA reporting system." FFIEC BSA/AML Examination Manual



WEBINAR TIME:
11:30AM - 1:30PM PT
12:30PM - 2:30PM MT
1:30PM - 3:30PM CT
2:30PM - 4:30PM ET

As of the end of last year, financial institutions were filing Suspicious Activity Reports (SARs) at the rate of about 31,000 a month. Overall, SAR filing rose about 30% from the preceding years. So, if banks are filing more SARs, are they doing a better job in the accurate and timely completion of those that they file? Apparently not.

FinCEN has been repeatedly criticized in audit reports from the Office of Inspector General (OIG) in connection with the quality of the SARs it receives from financial institutions. In its most recent report on the subject, the OIG projected that data quality problems existed in approximately 62% of SARs filed. Specifically, there was missing, incomplete, inappropriate or inconsistent information in a data field critical to law enforcement agencies. Previous OIG reports have noted that some SARs are simply unintelligible; it is very difficult to understand narratives supplied by some banks.

Finally, recently published FFIEC BSA/AML examination procedures clearly indicate that a bank's SAR filing decisions are to be respected, if the bank has:
-an established SAR decision-making process,
-followed existing policies, procedures and processes and
-determined not to file a SAR.

While such a statement qualifies as good news, it's easy to read over that fact that many banks do not have a discernable SAR decision making process or established SAR filing policies and procedures. Without them, it is unlikely that SAR filing decisions will be respected.

This webinar focuses on the legal requirements behind SAR filing, the design of a SAR filing process and the actual completion of the form. It's "basic training" for an effective SAR filing program.

Program content includes:

  • the form and its instructions,
  • what is suspicious activity,
  • Treasury requirements,
  • regulatory agency requirements,
  • filing triggers,
  • identifying and retaining supporting documentation,
  • describing the criminal activity,
  • the "safe harbor" provisions,
  • developing a SAR filing procedures,
  • developing a SAR filing policy,
  • reporting to the board of directors and
  • recent developments in SAR filing.

    Not Included
    This seminar addresses SAR filing for depository institutions. Specific SAR filing responsibilities for members of the securities industries, MSBs and casinos are not addressed. This is a technical presentation, not basic training on recognizing suspicious activity.

    Who Should Attend
    Program content is at the intermediate level and the expected audience is compliance, security and BSA officers. The program is expected to meet the needs of employees from banks, thrifts and credit unions; it is not designed

    The Manual
    The manual is designed to help attendees understand the law enforcement purposes behind the form and to complete it accurately.


    The Speaker:

    Ken Golliher is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection School for examiners. He has presented seminars in more than 25 states and has served as an instructor at compliance schools sponsored by the Illinois, Indiana, Georgia, Kansas, Kentucky, Nebraska, Pennsylvania and Texas bankers associations. He is one of the moderators for the Bank Secrecy Act forum at http://www.bankersonline.com/
    More information...


    Location: Webinar
    Price: $225 Early Bird - Registration one-week prior to the event
    Sponsor: BOL Learning Connect
    Contact: Carin Eisenhauer
    E-Mail: carin@bankersonline.com
    888-229-8872
       
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