Referrals
Narrative Rubric
Customer Outreach
Who Do I Refer to?
TMO Systems Guide
100

This may be necessary when an investigator determines that two or more legal entities, who share the same beneficial owner(s) are not operating independently of one another?

TIN Aggregation Referral (CTR@Capitalone.com)

100

Use this date when describing suspicious card activity.

Transaction Date

100

This is the amount of time before an alert or case must be decisioned after sending a Customer Outreach request.

10

100

The customer is 86 years old and account activity involves several out of pattern high-valued checks payable to an unrelated person for no apparent reason.

FEVA

100
The system used to find additional information on ACH transfers and ATM machine locations.

Acquire

200

Sent when an investigator encounters certain scenarios including an alert with data issues or an alert or alerted activity that could be a potential process improvement.

STAR Referral (starreferral@capitalone.com)

200

The email address used in the FIU Standard Closing Sentence.

AMLLERequest@capitalone.com

200

This is the number of days before a new Customer Outreach request can be sent to the KYC Team.

90 Days

200

During an investigation, you observe payroll deposits from Capital One.

Associate Referrals (SIU)

200

For Card Branded Book, this is the system where mailed-in payments can be located

Hubble

300

Scenarios including computer intrusion cases, embezzlement, any wire alert (including Non-CONA) that involves on of the eight Tier 1 SIU Countries, and substantial negative news may require a referral to this department.

SIU Referral 

NOTE: "Substantial" entails negative news related to Terrorist Financing or involvement in Terrorist Organization, Human Trafficking/Prostitution Ring, Organized Crime Rings, and Large Scale Negative News found in National Media, that require complex investigation, large scale SAR filing

300

Date alerted used for Adhocs/ACTs with no parent CWI

Item Date

300
This is strictly prohibited when sending Customer Outreach requests or seeking additional information.

Contacting the KYC Team or branch personnel

Note:  The response will be listed within the Refresh History in iCAN, as soon as a response is received.  If no response is received within 28 days, the Customer Outreach request is closed.

300

Any wire alert (including Non-CONA) that involves one of the following countries: UAE, Turkey, Pakistan, Lebanon, Ukraine, Iraq, Afghanistan, and Yemen.

SIU

300
This is an additional system accessed just for Card SAR Filings

Turing

400

Once it's determined that a full review is needed on 5 or more unrelated Capital One accounts and 10 or more counterparties with 3 or more transactions each are identified within the investigation this referral would apply.

Super Team Referral - Note: Unrelated is defined as not readily identified as an associated account.  The 10 or more qualifying counterparties can include any of the 5 or more Capital One accounts that need to be reviewed, as long as those counterparties conduct 3 or more transactions each.

 

400

R14

Internal Investigation Number

400
This field is at the beginning of the Customer Outreach template and is important for tracking and delineation from the consequence management process.

[RFI V1.0] - Helps prevent a customer's relationship from being incorrectly or inadvertently terminated.

400

Alert/Activity that could be a potential process improvement for a new NFA, rule logic, etc.

STAR Team

400

These are our two third-party payment processor services companies and their related systems which are utilized in Card investigations.  

CheckFree - Wells Fargo

Homebanking - Mastercard Connect

500

A referral is sent to this email address if you have NO Money Laundering concerns but there are enough Red Flags to indicate potential Fraud related to PPP or EIDL payments. 

AMLCOVIDTaskForce@capitalone.com

Then Non-Issue/No File your item as per your BAU process and send an email referral

 

500

SAR Filing Date is defined as...

Date which Capital One submits/sends the SAR Filing to FinCEN

500

This would indicate that an account is categorized as a Commercial relationship.

The cost center begins with 3

NOTE: There is a specialized procedure in place specific to customer outreach on commercial accounts and supervisor approval is required.

500

During the course of a Bank ML Investigation, if it is discovered that an owner/signer of an account is deceased but the account is currently open.

Bank Estate Operations

500
This system is used to export documentats that are part of the contract package of an Auto loan.

CLO