BSA Confidentiality Issues: Subpoenas, NSLs, Law Enforcement & Lawsuits
Understanding law enforcement inquiries and requests is an important part of a BSA Officer's job. Who can get the SAR? How do you give them the supporting documentation? Learn how you can establish policies, procedures, and processes for identifying subjects of law enforcement requests, monitoring the transaction activity of those subjects when appropriate, identifying unusual or potentially suspicious activity related to those subjects, and filing, as appropriate, SARs related to those subjects. Law enforcement inquiries and re-quests can include grand jury subpoenas, National Security Letters (NSL), and section 314(a) requests.
Also, mere receipt of any law enforcement inquiry does not, by itself, require the filing of a SAR by the bank. For example, the receipt of a grand jury subpoena should cause a bank to review account activity for the relevant customer. A bank should assess all of the information it knows about its customer, including the receipt of a law enforcement inquiry, in accordance with its risk-based BSA/AML compliance program. The bank should determine whether a SAR should be filed based on all customer information available.
Due to the confidentiality of grand jury proceedings, if a bank files a SAR after receiving a grand jury subpoena, law enforcement discourages banks from including any reference to the receipt or existence of the grand jury subpoena in the SAR. Rather, the SAR should reference only those facts and activities that support a finding of suspicious transactions identified by the bank.
Learn more during this program on the dos and don'ts on working with different types of law enforcement inquires.Covered Topics:
- A look at the SAR confidentiality law
- A review of who can get what and how to give the information
- What constitutes supporting documentation?
- What to do if you receive a subpoena
- How to handle National Security Letters
- How to handle a 314(a) match and when to file a SAR
- What to do if you have an OFAC match. Do you file?
- Whitney National Bank Case and resulting Interagency guidance
- Sharing with your Board of Directors
Who Should Attend:
BSA Officers, Coordinators, Compliance Officers, and Security Officers will benefit from attending this webinar.The Presenter:
Deborah Crawford is the President of gettechnical inc. She specializes in compliance and regulations for the deposit side of financial institutions. Her 20+ year career in banking and training began at Hibernia National Bank. She has been a seminar leader for many state associations and credit union groups across the nation. She has Bachelors and Masters degrees from Louisiana State University.
|Licenses / Designations / Educational Credits:||CEU|
All US States: 2.5
All Canadian Provinces: 2.5
|About The Provider:
||Since 1983 Total Training Solutions has produced dozens of videotapes, CD-Roms, DVD's and web-based training modules. In addition to off-the-shelf products, Total Training Solutions also develops custom training products and consults with financial institutions to develop their own training curriculum.
For timely delivery of training topics, webinars or web conferencing is an unbeatable option. We now offer over 100 live programs per year and you can even purchase the recorded or ondemand session if you are unable to attend the live program.
We have worked exclusively with the financial industry since our founding. Because of this, we understand the needs of training departments in financial institutions and are alert to changes which affect the industry.
Attend the live session with the opportunity to ask questions to the presenter. You also receive a link to the handouts. All registrations for a live event will be given access to the OnDemand recording, at no additional cost, for seven days following the event. This will allow a flexible alternative when last minute conflicts intrude on scheduled events.
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Includes all three options above. Live session, OnDemand Weblink, and CD-Rom plus Hardcopy Handouts.
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Includes two of the options above. Live session and 6 months access to OnDemand Weblink plus link to handouts.
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|BSA Confidentiality Issues: Subpoenas, NSLs, Law Enforcement & Lawsuits||CD/On-Demand||$325.00||
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