BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15

Checklist 6.1: Suspicious Activity Report (cont.)

Evaluating the SAR Decision-Makin Process — Part Two

Yes No

N/A

Does the institution have an individual responsible for preparing and filing SARs?

Y

Does the institution conduct employee training regarding SARs?

Y

Does the institution have a process for ensuring that transaction amounts are consistent with the type and nature of the business or occupation of the customer? Does the institution have a process for reviewing accounts that are exempted from CTR reporting for unusual or suspicious activity? Does the institution have a process for establishing expected activity levels (e.g., historical transaction pattern or input from client or officer), including who has the authority to change profiles? Does the institution have a process for reconciling activity levels of higher risk accounts against expected activity to ensure that activity levels are reasonable? Does the institution have a system for reviewing exception reports and determining what parameters are used to filter exceptions? Does the institution have a process for requesting timely and adequate explanations of activity generated by monitoring reports?

Y

Y

Y

Y

Y

Y

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