WASHINGTON — In its latest SAR Activity Review–Trends, Tips, & Issues, the Financial Crimes Enforcement Network found inconsistencies among shared branch suspicious activity report filings.
“The number of filer-name and [Federal Employer Identification Numbers] in BSA filing related to these cooperatives could complicate future efforts to correctly identify and aggregate SAR filings involving the cooperatives and their affiliated entities. Data consistency problems and other data-quality issues prolonged and hindered efforts to collect and evaluate data for this analysis,” the report read. In many cases, FinCEN found, the filing institution already has the correct information on hand.
NAFCU Director of Compliance Anthony Demangone said the report does not necessarily mean this will be a new area of focus for FinCEN but it raises a “red flag” for him. “If I'm in a shared branch, that's going to be on my to do list,” he commented.
Financial Services Center Cooperative, Inc. Executive Vice President/Chief Operating Officer Bonnie Kramer explained that her organization requires training for new credit unions as they sign up. They also offer follow up training that is highly recommended. FSCC's policy on BSA filings outlines the necessary reports to be filed and states that they must be filed with FinCEN in a timely manner, she said.
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