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Suspicious Activity Detecting, Investigations, Monitoring,
and Reporting
The detection, investigation, monitoring
and reporting of suspicious activity and transactions
should be at the very center of any firm’s anti-money
laundering (AML) program.
Since 1996, all U.S. banks and banking firms (and, since
2002, their subsidiaries (e.g. broker-dealers, money transmitters,
insurance)) have been required by federal law to provide
financial regulators and law enforcement with referrals
regarding possibly suspicious customer transactions (money
laundering, structuring, check fraud, loan fraud, computer
intrusion, terror financing) and insider/employee frauds
(defalcation, embezzlement, mysterious disappearance, misuse
of position).
This responsibility has been especially
challenging because for many years there were no common
definitions or standards, and no detailed instructions
on when and how to file SARs. Also, there have been mixed
signals on “detection,” the
proper trigger events on SAR filing, as well as the possible
consequences to the company for filing a SAR in error.
CRI’s expertise can be invaluable
in supporting your Board of Directors, financial and
legal advisers in the myriad decisions surrounding SAR
filing.
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