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5 Cards in this Set

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U2 Suspicious Activity Report

Suspicious Activity Reports (SARs)SARs are the tool used to implement AML Policy. The BSA imposes both a mandatory and voluntary requirement to file them. All filings are to be done electronically at: http://bsaefiling.fincen.treas.gov/main.html. Required filings are triggered by certain criteria published by FinCEN. Additional information on the topic can be found athttp://www.fincen.gov/statutes_regs/guidance/html/reg_faqs.html. When to file: A SAR shall be filed no later than 30 calendar days after the date of the initial detection Penalties for Non-Compliance1. Civil Penalties:Failure to comply with record keeping requirements: up to $1,000 per violation.Failure to comply with reporting requirements: not to exceed the greater of the amount involved in the transaction - not to exceed $100,000) or $25,000.Cease and desist order if continued noncomplianceForfeiture of assets. 2. Criminal Penalties for Noncompliance:A person willfully violating the BSA shall be fined not more than $250,000, or imprisoned for not more than five (5) years, or both.A person willfully violating the BSA while violating another law of the United States or as part of a pattern of any illegal activity involving more than $100,000 in a 12 month period shall be fined not more than $500,000, imprisoned for no more than 10 years, or both. A separate violation occurs for each day the violation continues and each office, branch or place of business at which a violation occurs or continues.

U2 Suspicious Activity Report QUESTION

Failure to comply with Anti-Money Laundering record keeping requirements will result in up $____________ per violation.( )$500( )$1,000( )$2,500( )None of theseExplanation:Penalties for Non-Compliance1. Civil Penalties:Failure to comply with record keeping requirements: up to $1,000 per violation.Failure to comply with reporting requirements: not to exceed the greater of the amount involved in the transaction - not to exceed $100,000) or $25,000.Cease and desist order if continued noncomplianceForfeiture of assets. 2. Criminal Penalties for Noncompliance:A person willfully violating the BSA shall be fined not more than $250,000, orimprisoned for not more than five (5) years, or both.A person willfully violating the BSA while violating another law of the United States or as part of a pattern of any illegal activity involving more than $100,000 in a 12 month period shall be fined not more than $500,000, imprisoned for no more than 10 years, or both.

1 SAR Confidentiality

SAR Confidentiality http://www.fincen.gov/news_room/nr/html/20120206.htmlCurrent and former employees, are prohibited from disclosing SARs, or any information that would reveal the existence of a SARThe unauthorized disclosure of SARs is a violation of federal lawMay be subject to civil and criminal penaltiesViolations may be enforced through civil penalties of up to $100,000 for each violation and criminal penalties of up to $250,000 and/or imprisonment not to exceed five years AuditsBoth the Consumer Finance Protection Bureau (CFPB) and the IRS are authorized to carry out audits of your policies, procedures, training records, and reports.

2 Record Production Requirements

Record Production RequirementsUpon receiving an information request from FinCEN, the owner shall expeditiously search its records to see if it has or had any account or engaged in any transaction with those named in FinCEN's request. Records must be maintained for 5 years. The information may include:Any current account maintained for a named suspect;Any account maintained for a named suspect during the preceding twelve months;Any transaction conducted by or on behalf of a named suspect, or any transmittal of funds conducted in which a named suspect was either the transmitter or the recipient, during the preceding six months.

2 Record Production Requirements QUESTION

Anti-Money Laundering regulations require records to be maintained for ______ years.( )2( )3( )5( )7Explanation:2 Record Production RequirementsRecord Production RequirementsUpon receiving an information request from FinCEN, the owner shall expeditiously search its records to see if it has or had any account or engaged in any transaction with those named in FinCEN's request. Records must be maintained for 5 years. The information may include:Any current account maintained for a named suspect;Any account maintained for a named suspect during the preceding twelve months;Any transaction conducted by or on behalf of a named suspect, or any transmittal of funds conducted in which a named suspect was either the transmitter or the recipient, during the preceding six months.