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Internal Suspicious Activity Report

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It is critical for staff to overcome the temptation to ignore strange behavior or explain it away. People find it much more tempting to explain away the behavior by making assumptions in favor of the member and the member's peculiar behavior.
Confidentiality
SARs are Highly Confidential! Neither the completion nor submission of an Internal Suspicious Activity Report should indicate whether an official SAR has or has not been filed. The determination of whether to file or not file a SAR is made by the BSA Compliance Officer and the confidentiality of the filing decision is maintained within the Compliance Department.
Never disclose to a member that an ISAR has been completed or submitted. If we are suspicious of activity, we do not want to “tip-off” the subject because they may stop or move their scheme to a different institution.
If an …show more content…

While we may file a SAR for any amount at our discretion, we are required by law to file a SAR for the following dollar amounts:
 Criminal violations involving insider abuse in any amount
 Criminal violations aggregating $5,000 or more when a suspect can be identified
 Criminal violations aggregating $25,000 or more regardless of a potential suspect
In cases where our members have been victims of fraud, such as from investment fraud, we may not know the identity of the suspect. In that case, we should only file if the fraud amount was a minimum of $25,000.
Immediate Action Required
We must report suspicious activity that may involve money laundering, BSA violations, terrorist financing, and certain other crimes above prescribed dollar thresholds. If you know, suspect, or have reason to suspect that a member may be linked to terrorist activity against the United States, management should notify the BSA Department who will immediately call:
FinCEN’s Financial Institutions Terrorist Hotline:

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