Martha Whitmire, the BSA Compliance Officer for First National Bank, is responsible for monitoring the bank's daily currency activity and wire transfers, for compliance with information retention and reporting requirements. Ms. Whitmire notices during her review on March 10 that, during the previous two weeks, a transaction occurred on the same account several times during the week. The activity appeared at one branch office as cash deposits in dollar amounts under the reporting thresholds. Ms. Whitmire discusses this activity with the branch manager and determines that this same deposit activity occurred several times during the previous six weeks. She then conducts a more extensive examination of the account's activity for several months and discovers that cash deposits were made at one branch office and purchases of bank cashiers checks were made by withdrawals from the same account at a different branch office. All withdrawals and purchases of cashier's checks were for the identical amount as the cash deposits. Which statement best describes Ms. Whitmire's responsibility?
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A. B. C. D.D
Martha Whitmire, the BSA Compliance Officer for First National Bank, is responsible for monitoring the bank's daily currency activity and wire transfers, for compliance with information retention and reporting requirements. During her review on March 10, she noticed that a transaction occurred on the same account several times during the week over the past two weeks. The activity appeared at one branch office as cash deposits in dollar amounts under the reporting thresholds.
According to the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations, financial institutions are required to file a Currency Transaction Report (CTR) for any cash transactions of $10,000 or more in a single business day. Therefore, Ms. Whitmire should consider filing a CTR for each of the cash activities at the branch office, as they appeared to be structured to avoid the $10,000 reporting threshold.
Ms. Whitmire discusses this activity with the branch manager and determines that this same deposit activity occurred several times during the previous six weeks. She then conducts a more extensive examination of the account's activity for several months and discovers that cash deposits were made at one branch office and purchases of bank cashiers checks were made by withdrawals from the same account at a different branch office. All withdrawals and purchases of cashier's checks were for the identical amount as the cash deposits.
The suspicious nature of the transactions raises concerns regarding the possibility of money laundering or other illicit activities. Therefore, Ms. Whitmire should report the account activity as suspicious account activity and recommend that a Suspicious Activity Report (SAR) be filed. A SAR is a report that financial institutions are required to file with the Financial Crimes Enforcement Network (FinCEN) to report any suspicious transactions that may indicate criminal activity. SARs must be filed within 30 days of detecting the suspicious activity, and it is important to note that the 15-day reporting deadline is for CTRs, not SARs.
In conclusion, based on the information provided, the best course of action for Martha Whitmire is to complete a CTR for each of the cash activities at the branch office, report the account activity as suspicious account activity, and recommend that a SAR be filed.