BSA/AML Examiner School - Case Study Oct 2023

LCB12/15

Checklist 6.1: Suspicious Activity Report (cont.)

Yes No

N/A

• Procedures for documenting decisions not to file an SAR?

Y

• Procedures for considering closing accounts as a result of continuous suspicious activity? • Procedures for completing, filing, and retaining SARs and their supporting documentation? • Procedures for reporting SARs to the board of directors, or a committee thereof, and senior management? • Procedures for sharing SARs with head offices or controlling entities?

Y

Y

Y

Y

Comments: SAR Reporting — All employees are required to report any suspicious activity by a customer or an employee to their supervisor or a bank officer. All SARs filed are to be reported to the Bank's Board of Directors or Audit Committee at the next scheduled meeting. If the suspect is a director or executive officer, all directors, exclusive of the suspect, will be notified immediately. SAR Committee — The Bank does not have a formal SAR Committee. Non-filing of SARs — According to the Bank's policy, any suspicious activity that is not filed will be documented and the records maintained.

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