Bank Secrecy Act (BSA) (supplemental front-line training)

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Bank Secrecy Act (BSA)(supplemental front-line
training)
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Bank Secrecy Act (BSA)Topics

• Suspicious Activity Report (SAR)
• Monetary Instrument Log
• Currency Transaction Report (CTR)

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Suspicious Activity Report (SAR)

• In general, we must file a SAR for
  transactions...
• involving funds derived from illegal activity
• intended to hide or disguise funds derived from
  illegal activity
• designed to evade the requirements of the BSA
• that appear to have no business purpose or that
  vary so substantially from normal activities
  appropriate for the particular member as to have
  no reasonable explanation.

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Suspicious Activity Report (SAR)

• After becoming aware of suspicious activity, a
  SAR must be filed within 30 calendar days.
• We may not inform the member a SAR will be filed.
• Actually, no one needs to know except you and
  Sarah Boyer, Kembas Compliance Officer.
• SARs at Kemba are located on the Intranet under
  the Documents/Forms tab. Forward completed SAR
  to Sarah Boyer. Please be sure to include a
  description of the suspicious activity in the
  narrative section.

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Monetary Instrument Log

• Credit unions are required to keep certain
  records of transactions involving the purchase of
  monetary instruments (credit union checks,
  cashier checks, money orders, travelers checks)
  with 3,000 - 10,000 in currency.
• Each branch has a log with the following info...
• date of purchase
• members name and account number
• type of instrument(s) purchased
• serial of each instrument purchased
• dollar amount of each instrument purchased
• Identification (list issuing state and ID ) if
  member is known to teller performing transaction,
  may check known instead

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Monetary Instrument LogRecordable Transactions

• Only write required transactions in the Monetary
  Instrument Log. The following constitute a
  required transaction a person brings in an
  aggregate of 3,000 through 10,000 in cash
  during a business day and purchases one or more
  of the following items with these funds
• Kemba Official Check
• Kemba Cashiers Check
• Money Order
• Travelers Check
• IMPORTANT If you deposit the funds into the
  members account then perform a withdrawal of
  these funds to issue the member a monetary
  instrument, such a transaction would be included
  on the log.

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Monetary Instrument LogNon-Recordable
Transactions

• Please do not record any non-required transaction
  on the Monetary Instrument Log. For example,
  none of the following should be listed on the
  log
• Straight Cash Withdrawal
• Straight Cash Deposit
• Straight Check Withdrawal
• Cashing a Check

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CURRENCY TRANSACTION REPORT (CTR)Getting to Know
the CTRPerson(s) Involved in Transaction

• Part I, Section A
• On Whose Behalf Conducted
• Occupation must be specific
• Must obtain ID info regardless of whether you
  know member and must record this info on the CTR
• Make copy of ID and send to Sarah Boyer along
  with completed CTR

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Correct
10
Incorrect
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Getting to Know the CTRPerson(s) Involved in
Transaction

• Part I, Section B
• Who is Conducting Transaction
• (if different from Section A)
• If conducted on own behalf, must check that box
• If conducted on behalf of another (for example,
  conducted by a Power of Attorney)...
• Must obtain ID regardless of whether you know
  individual conducting transaction and record info
  on CTR
• Make copy of ID and send to Sarah Boyer along
  with completed CTR

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Correct
13
Incorrect
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Getting to Know the CTRAmt Type of Transaction

• Part II
• Please be sure to include date of transaction
• Amount always should be rounded up
• For example, 10,152.07 10,153
• Boxes 30-34 36 (at least one of these boxes
  needs to be checked if box 36, describe the
  other.

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Getting to Know the CTRAmt Type of Transaction
(Part II, cont)

• Box 35 (Acct Numbers affected, if any)
• Examples
• A person cashes a check drawn on an account held
  at Kemba indicate negotiable instrument(s)
  cashed and provide the account number of the
  check.
• A person cashes a check drawn on another
  financial institution indicate negotiable
  instrument(s) cashed but leave box 35 empty
  because no account at the financial institution
  has been affected.

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Correct
17
Incorrect
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Getting to Know the CTRFinancial Institution
Information

• Part III
• some fields are already populated on the CTR form
  located on Kemba Intranet
• Address should be branch where transaction
  occurred
• Approving official...preferably Branch Supervisor
  or Branch Manager head teller if supervisor not
  available
• Date of signature
• Type form if need to handwrite PRINT NEATLY

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Multiple Persons

• Joint Accounts
• All account holders present at transaction should
  be included on CTR.
• All account holders should be included on CTR
  even if not present at transaction. (This
  requirement applies to both deposit and
  withdrawal transactions.)
• Exception you have specific information that
  transaction only benefits account holders
  conducting transaction. You will need to supply
  Compliance Officer with a summary of this
  information.

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Multiple Persons (joint accts-cont)

• The account holders are listed in Section I, Part
  A. Use the continuation page(s) if more than one
  account holder. Account holder is not listed in
  Part B of Section I.
• Obtain occupation of account holders not present
  at the transaction.
• For account holders not present...under ID
  portion, check the other box and type N/A on
  the line.

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Summary Review of CTR

• Account holders are listed in Part A and not Part
  B.
• All account holders must be listed unless
  exception applies.
• Occupation must be specific. For example,
  self-employed is not acceptable.
  Self-employed builder is acceptable.
• ID must always be obtained and recorded for
  person(s) conducting transaction regardless of
  whether known to teller.
• Double check completed CTR, then forward it to
  Compliance Officer, Sarah Boyer. (CTR must be
  filed with govt within 15 days.)
• If member is conducting transaction on own
  behalf, be sure to check that box in Part I,
  Section B.
• Part II-Amt Type of Transaction if you check
  the other box, a description is required on the
  corresponding lines.

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QUESTIONS

• Please contact Sarah Boyer, extension 1897, if
  you have any questions.