Common use of Detecting and Reporting Suspicious Activity Clause in Contracts

Detecting and Reporting Suspicious Activity. Associates have a duty to understand their responsibilities for detecting and reporting suspicious activity. It is the requirement of RCS Third Party that Associates follow established “Know Your Customer” (or KYC) procedures; that any customer, Associate, or other suspicious activity (or possible suspicious activity) be promptly reported to designated persons as set forth in the Requirements; that all such reports be timely and diligently investigated by such designated persons; and to timely and comprehensively fulfill all suspicious activity report filing requirements by providing proper notice to RCS Third Party BSA/AML Compliance Officer. Any suspicious activity identified by RCS Third Party should be reported to the Bank’s Non-Traditional BSA Manager or designated BSA Staff in a timely manner upon identification via the established agreed upon reporting mechanism. RCS Third Party shall require that all Associates should maintain the strict confidentiality of all such suspicious activity investigations and reports. In pursuit of its obligations to diligence and oversight, RCS Third Party should develop or acquire tools for use in reviewing account activity. These tools, when deployed in conjunction with a formal risk management training program should represent a broad spectrum approach to detecting and reporting suspicious activity. Per the Requirements, tools and resources should include the following:

Detecting and Reporting Suspicious Activity. Associates have a duty to understand their responsibilities for detecting and reporting suspicious activity. It is the requirement of RCS Third Party that Associates follow established “Know Your Customer” (or KYC) procedures; that any customer, Associate, or other suspicious activity (or possible suspicious activity) be promptly reported to designated persons as set forth in the Requirements; that all such reports be timely and diligently investigated by such designated persons; and to timely and comprehensively fulfill all suspicious activity report filing requirements by providing proper notice to RCS Third Party BSA/AML Compliance Officer. Any suspicious activity identified by RCS Third Party should be reported to the BankFB’s Non-Traditional BSA Manager or designated BSA Staff in a timely manner upon identification via the established agreed upon reporting mechanism. RCS Third Party shall require that all Associates should maintain the strict confidentiality of all such suspicious activity investigations and reports. In pursuit of its obligations to diligence and oversight, RCS Third Party should develop or acquire tools for use in reviewing account activity. These tools, when deployed in conjunction with a formal risk management training program should represent a broad spectrum approach to detecting and reporting suspicious activity. Per the Requirements, tools and resources should include the followingdaily application reviews of: