Suspicious Activity Monitoring and Reporting. 3. Within 60 days of this Agreement, the Bank and the Branch shall jointly submit a written program acceptable to the Supervisors to reasonably ensure the identification and timely, accurate, and complete reporting by the Branch of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. At a minimum, the program shall include:
Suspicious Activity Monitoring and Reporting. (1) Within one hundred twenty (120) days of this Agreement, the GM shall ensure that the Branch develops, implements, and thereafter adheres to an enhanced written risk-based program of internal controls and processes to ensure, pursuant to 12 C.F.R. § 21.11, the timely and appropriate review and disposition of BSA/AML suspicious activity alerts and the timely filing of Suspicious Activity Reports (“SARs”). This written Branch program shall include, at a minimum:
Suspicious Activity Monitoring and Reporting. 5. Within 60 days of the Agreement, SSC and the Bank shall jointly submit a written revised program acceptable to the Supervisors to reasonably ensure the identification and timely, accurate, and complete reporting by SSC, its nonbank subsidiaries, and the Bank, as applicable, of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. At a minimum, the revised program shall include:
Suspicious Activity Monitoring and Reporting. Banks are required to report suspicious activity that may involve money laundering, BSA violations, terrorist financing, and certain other crimes above prescribed dollar thresholds. Any customer or transaction that fails any stage of Prosper’s verification procedures or that exhibits other risk factors is manually reviewed by Pxxxxxx’s Risk team. As a part of this process, if Pxxxxxx knows, suspects, or has reason to suspect, (1) insider abuse (in any amount), or (2) any suspicious transaction involving a violation of federal law of $5,000 or more, Pxxxxxx will aid WebBank in filing its Suspicious Activity Report (“SAR”) by providing sufficient information for WebBank to complete its Treasury Form TD F 90-22.47. Prosper will develop and maintain sufficient operational procedures to allow its employees to identify red flags for suspicious activity, including when transactions are: · Obtained from illegal activity · Intended or conducted to hide or disguise funds or assets derived from illegal activity · Designed to evade any reporting requirements of the Bank Secrecy Act (BSA) · Transacted with no business or lawful purpose · Not the sort the customer normally engages · Pxxxxxx knows of no reasonable explanation for the transaction after examining available facts including the background and possible purpose of the transaction Exhibit I Bank Secrecy Act Policy Pxxxxxx, its directors, officers, employees, and agents will not notify any person involved in the suspicious transaction that information has been provided to WebBank for purposes of filing a SAR, or that a SAR has been reported. Prosper shall retain the information provided to WebBank for the purposes of filing SARs and any supporting documentation for five (5) years from the date the information was reported.
Suspicious Activity Monitoring and Reporting. (1) Within ninety (90) days of the date of this Agreement, the Board shall ensure the Bank develops, implements, and thereafter adheres to an acceptable, written program to ensure the timely and appropriate review and disposition of suspicious activity alerts and case investigations and the filing of suspicious activity reports (“SAR”) consistent with 12 C.F.R. § 21.11 (“Suspicious Activity Monitoring and Reporting Program”). At a minimum, this written program shall:
Suspicious Activity Monitoring and Reporting. 6. Within 60 days of the effective date of this Agreement, the Bank shall submit a written revised program acceptable to the Reserve Bank to reasonably ensure the identification and timely, accurate, and complete reporting by the Bank of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. The revised program shall include the following four items:
Suspicious Activity Monitoring and Reporting. 6. Within 90 days of this Agreement, DFS shall submit a written program acceptable to the Reserve Bank to reasonably ensure the identification and timely, accurate, and complete reporting of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities for transactions at, by, or through DFS or its nonbank subsidiaries, as required by section 225.4(f) of Regulation Y of the Board of Governors (12 C.F.R. § 225.4(f)). At a minimum, the program shall include:
