BSA-AML Examiner School Case Study eBook

Internal Use Only

BSA/AML Policy and Program

The BSA/AML/OFAC function will review all accounts on which a SAR has been filed for potential account closure. Unless authorized by the BSA/AML Officer in writing to stay open, any account that is subject to repeat SAR filings will be closed. In the event that the account remains open, TS&J will: ● Treat all customers on which a SAR has been filed as high risk and subject to EDD for a minimum of three years; and ● Track all related accounts for a period of 90 days from the date of the SAR filing to determine whether there is continuing activity that warrants the filing of a continuing activity SAR. SAR Confidentiality It is illegal for TS&J and any of its Bank employees to notify any person involved in a transaction that a SAR has been filed. A SAR and any information that would reveal the existence of a SAR are confidential. TS&J strictly prohibits all Bank employees from: ● Disclosing the existence, or possible existence, of a SAR to any party; and ● Tipping off any customers or related parties that they are or have been the subject of an investigation. Any person subpoenaed or otherwise requested to disclose a SAR or the information contained in a SAR, except when such disclosure is requested by FinCEN or an appropriate law enforcement or federal banking agency, must immediately escalate the matter to the BSA/AML Officer and General Counsel and take no other action pending further direction from those parties. If the BSA/AML Officer and General Counsel determine the request is not permissible, TS&J will decline to produce the SAR or to provide any information that would disclose that a SAR has been prepared or filed, citing 31 CFR 1020.320 and 31 USC 5318(g)(2) as appropriate. UAR Requirements for Critical Third Parties The BSA/AML Officer oversees the timely review of referrals from Critical Third Parties, including Fintech Partners, who will send an Unusual Activity Report (“UAR”) to TS&J in any circumstance where it believes activity is potentially suspicious and may involve: ● Criminal violations involving insider abuse in any amount; ● Criminal violations aggregating $5,000 or more when a suspect can be identified; ● Criminal violations aggregating $25,000 or more regardless of a potential suspect; or

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Confidential