The SAR Decision Making Process – Now What?
Just as your BSA/AML program has 4 pillars, so should your suspicious activity reporting process.
This program focuses on how to develop, maintain, and document just such a process.
The FFIEC BSA/AML Exam Handbook contains an entire section on “The SAR Decision Making Process.” In reviewing your bank’s SARs, the examiners are directed to “…focus on whether the bank has an effective SAR decision-making process, not individual SAR decisions.” Without a strong, written process, your program is at risk for criticism for every SAR not filed. How would your bank’s procedure and process hold up under the scrutiny of an examiner, auditor or other third-party?
There are countless questions to address before designing and implementing the SAR decision making process, including:
- How do you document something you did not do, such as for a SAR not filed?
- What is needed to support a filed SAR?
- Who should make the SAR filing decisions?
- How much time is permitted to file on an identified unusual activity?
- When does the SAR filing “clock” start ticking?
Just as your BSA/AML program has 4 pillars, so should your suspicious activity reporting process. This program focuses on how to develop, maintain, and document just such a process.
- Identification or alert of unusual activity (which usually result from employee identification, law enforcement inquiries, other referrals and transaction and surveillance monitoring systems).
- Managing and reviewing alerts
- SAR decision making
- SAR completion and filing
BSA/AML officers, risk management officers, compliance officers and auditors.
Patricia Cashman, CRCM, Cashman Compliance Solutions, LLC, began her banking career in 1969. She was the senior operations officer for three community banks, assistant examiner for the Texas Department of Banking and manager of the compliance/audit division of one of the largest bankers’ banks in the country. Additionally, Patricia has taught a variety of compliance subjects at state and national banking schools and webinars, and she has been a trainer for numerous banks and compliance organizations.
Institute of Certified Bankers: Visit ICB Webpage for instructions regarding self-reporting. Institute of Certified Bankers: Estimated credits: 2.5 hours CRCM (self-reporting).
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