SARs/CTRs
What does SAR stand for?
Suspicious Activity Report
What is the category recently added in the Business BSA Risk Grading Matrix?
Does the business generate any of their income from the sale of THC?
It was added with a very high score if the answer is Yes so the customer would automatically score as a high risk customer.
What does OFAC stand for?
Office of Foreign Assets Control
What does BSA stand for?
Bank Secrecy Act
Where can you find the banks BSA Policy, Privacy Policy, Information Security Policy, CIP Policy and more?
Shared Drive > Bank Policies folder
If the owner of the local car wash is depositing over $10,000 cash every week, what form(s) should you file?
CTR & SAR
CTR because is it OVER $10,000
SAR because is it normal for a cash wash to take in that much cash every week?
For purposes of Beneficial Ownership reporting, a legal entity includes what types of businesses?
Corporation, LLC, General Partnership (or other entity created by a filing of a public document with the Secretary of State).
Legal Entity does NOT include sole proprietorships, unincorporated associations or natural persons opening accounts on their own behalf.
What system do we use to get all customer names in our our database for ongoing "scrubbing"?
FIS eFunds
Unless an exemption applies, all cash transactions totaling over this amount in one business day require a CTR filing.
$10,000
This means OVER $10,000. A CTR would not be filed if the cash amount is exactly $10,000... a SAR may be considered.
The best way to dispose of customer-sensitive information and report is:
Shredding
For purposes of determining CTR filing, what day should you consider a deposit made on a Tuesday at 4:10 PM?
The next business day after Tuesday, typically that Wednesday. The cash deposit amount needs to be added together with any other cash deposits made on that next business day.
In what case(s) would you not be able to use a drivers license to verify a person's identity?
If it's expired.
What should you do if you get an OFAC Fail when doing the OFAC check?
Carefully review the information. If there is any indication that it is a positive match, you may not proceed with account opening or loan closing.
If it looks to be a false positive, you must get approval to move forward from the BSA Officer. Approval of override must be documented on paperwork.
A customer deposits $10,000 cash from their checking and withdraws $50,000 cash from their savings. What dollar amounts are included on the CTR filing?
When not in use, customer-sensitive information should be stored in:
Locked drawers, vaults and locked file cabinets.
Any dollar amount.
Other than a drivers license, what are other acceptable documents to use to verify a person's identity:
Passport, other government-issued photo identification
What is the dollar limit for blocking transactions for anyone on the OFAC list?
$0 - there is no minimum or maximum $ threshold for transactions subject to OFAC regulations.
What is the act of manipulating a cash deposit or withdrawal to avoid the filing of a CTR?
Structuring
What should be done when a vendor needs access to the building?
Confirm by asking for identification that they are who they say they are, have them sign the log and physically escort them to the area they need to be. In most cases, an employee should remain present with the vendor at all times.
A bank can exempt certain customers from CTR filing. How many exempt customers does Bluff View Bank have?
6
Express Mart, Fergusons Morningside Orchard, West Prairie Winery, Frenchville Trailer Sales, Lakeside Restaurant (Blue Moon), Eckers Apple Orchard
You completed the Risk Grading Matrix during the completion of opening a new deposit account. What's the highest level a customer can still be considered in the "Normal" range?
1.80
1.81 - 2.25 = Medium (approval by officer needed)
above 2.26 = High (approval by BSA officer needed)
The OFAC list, which is distributed by the department of the Treasury, must be checked:
For any new customers at account opening, and entire database at least monthly.
The BSA requires the bank to obtain this for all customers opening a deposit account or obtaining a loan if they are a US person or US Business Entity.
How would you send an email with sensitive or confidential information? (encrypted)
Use the word "secure" in the subject line.