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Rules and thresholds only go so far. The way most bankers actually learn suspicious activity reporting is by working through cases: what the activity looked like, what made it suspicious, which rule applied, how fast the bank had to move, and what the narrative needed to say.

This article walks through six suspicious activity report examples drawn from the typologies banks see most often. Every case below is fictional and illustrative. The names, amounts, dates and ...

Structuring is the federal crime of breaking up or arranging cash transactions to keep a bank from filing a currency transaction report. It is the offense the CTR rules created: once Congress required banks to report cash over $10,000, people with reasons to avoid that report started splitting deposits, spreading them across branches and days, and recruiting friends to make them. Congress responded by making the evasion itself illegal, regardless of where the money came from.

For ...

A suspicious activity report, almost always shortened to SAR, is a confidential report a bank files with the Financial Crimes Enforcement Network (FinCEN) when it knows, suspects, or has reason to suspect that a transaction involves illegal funds, is designed to get around federal reporting rules, or makes no sense for the customer conducting it. It is the central reporting tool of the Bank Secrecy Act, and it is the one report in banking that the customer is never allowed to know ...

Most bankers know Regulation CC by its hold chart. Fewer have read the statute underneath it, and that gap shows up in the wrong places: in a policy that cites the regulation for something only the statute says, in a training session that treats a Board interpretation as if Congress wrote it, or in a compliance file that cannot explain why the dollar amounts changed on July 1, 2025.

The Expedited Funds Availability Act is short. It runs from 12 U.S.C. 4001 to 4010, ten sections in ...

When a joint owner dies, the surviving customer at the desk usually expects one answer: the money is mine now. Often that is right. A joint account with right of survivorship passes to the surviving owner outside probate, and the bank's job is mostly to retitle the account and clean up the records. But "joint" on a statement does not always mean survivorship, and a second name on the account does not always mean a second owner. The cases where those differ are the ones that end in a dispute ...

A payable-on-death designation is about the simplest estate planning tool a customer can get, and that simplicity is why so many end up in dispute. The customer adds a name at the desk or on a screen, nobody thinks about it again for twenty years, and the bank gets the death certificate. Then the account records, state law and the deposit agreement have to answer who gets paid, how much and on what proof. Usually the employee answering that has never seen how the designation was set ...

"Dormant" and "inactive" are used interchangeably at the branch, on statements and in core system menus, and that is where many escheatment errors begin. One word usually describes an internal status the bank chose for its own reasons. The other, when it is used precisely, describes a legal condition under a state's unclaimed property law that starts a reporting obligation. The two run on different clocks, are reset by different events, and lead to different consequences.

This post ...

Escheatment is the process by which property that its owner has stopped claiming is turned over to a state. For a bank, it is not an abstract legal concept. It is an annual operational cycle that touches deposit accounts, official checks, safe deposit boxes, loan credit balances and the bank's own uncashed vendor and payroll checks. Somebody in deposit operations or compliance has to find the property, try to reach the owner, file a report in each state that has a claim to it, and send the ...

Ask a room of mortgage lenders what "mortgage loan originator certification" means and you will get three different answers. A loan officer at a credit union will describe an NMLS registration. A loan officer at an independent mortgage company will describe 20 hours of pre-licensing education, a proctored test and a state license. A recruiter will describe a certificate program from a training provider. All three are real, and they are not interchangeable.

The difference comes down ...

Ask a new compliance analyst what "regulatory reporting" means and you will usually get one of two answers. Someone who came from finance says the Call Report. Someone who came from the BSA side says CTRs and SARs. Both are right, and both are describing a small part of the picture.

Bank regulatory reporting is the full set of recurring and event-driven filings a bank sends to government agencies about its condition, its lending, its customers' transactions and its tax-reportable ...

Ask ten bankers to define enhanced due diligence and most will describe a longer questionnaire. That is the least important part of it. Enhanced due diligence (EDD) is the additional understanding a bank builds about a customer whose risk is higher than its standard due diligence is designed to handle, and, just as important, the additional controls it applies as a result.

The term covers two quite different things in U.S. banking. A small set of relationships trigger EDD because a ...

Few BSA topics have generated as much confusion over the last few years as "beneficial ownership." Part of the reason is that the phrase now describes two different obligations owned by two different parties. One is a bank obligation: the customer due diligence (CDD) rule requires banks to identify and verify the people who own and control their legal entity customers. The other was a company obligation: the Corporate Transparency Act (CTA) required many businesses to file beneficial ...

Most people meet the securities licensing system as a list of numbers: Series 6, 7, 63, 65, 66, 24. Lists like that hide the structure underneath, and the structure is what tells you which exams you actually need, in what order, and who has to sign off before you can take them.

There are really two systems layered on top of each other. FINRA runs the qualification exams that let a person register with a broker-dealer. NASAA, the association of state and provincial securities ...

The Securities Industry Essentials exam, almost always shortened to the SIE, is the front door to every FINRA representative registration. If you work in a bank and have ever thought about moving to the investment desk, the bank's brokerage affiliate, or a platform role selling funds and annuities, the SIE is the first exam you will meet. It is also the only one you can take entirely on your own.

That last point is what makes the SIE different from everything else in the securities ...

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