BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 6.1: Suspicious Activity Report (cont.)

Evaluating the SAR Decision-Making Process — Part One

Yes No

N/A

Review the institution's policies, procedures, and processes for referring unusual activity from all business lines to the personnel or department responsible for evaluating unusual activity. Does the process ensure that all applicable information (e.g., criminal subpoenas, NSLs, and section 314(a) requests) is effectively evaluated? Do the policies, procedures, and processes require appropriate research when monitoring reports identify unusual activity? Does the institution's SAR decision process appropriately consider all available customer due diligence (CDD) information? Perform the procedures in Checklist 6. 4, "SAR Decision-Making Process." On the basis of these procedures, are the policies, procedures, and processes adequate to meet regulatory requirements associated with monitoring, detecting, and reporting suspicious activity? Based on a review of SARs, do any accounts or functional areas of the institution require further investigation? If so, are there any weaknesses in these areas that require strengthening to address known suspicious activities? Should any additional SARs be filed for any suspicious activity noted during the review? Based on a review of various reports for any transactions that appeared suspicious and met the reporting threshold, was a SAR filed?

Y

Y

Y

NA

NA

NA

NA

NA

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